CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD CENTRAL VALLEY REGION

CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
CENTRAL VALLEY REGION
11020 Sun Center Drive, #200 Rancho Cordova, California 95670-6114
Phone (916) 464-3291  Fax (916) 464-4645
http://www.waterboards.ca.gov/centralvalley
ORDER R5-2012-0115
NPDES NO. CA0079154
WASTE DISCHARGE REQUIREMENTS FOR THE
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
SAN JOAQUIN COUNTY
The following Discharger is subject to waste discharge requirements as set forth in this Order:
Table 1. Discharger Information
Discharger
Name of Facility
City of Tracy
Tracy Wastewater Treatment Plant
3900 Holly Drive
Facility Address
Tracy, CA 95304
San Joaquin County
The U.S. Environmental Protection Agency (USEPA) and the Regional Water Quality Control Board have classified
this discharge as a major discharge.
The discharge by the City of Tracy from the discharge points identified below is subject to
waste discharge requirements as set forth in this Order:
Table 2. Discharge Location
Discharge
Effluent
Discharge Point
Point
Description
Latitude
001
Treated Wastewater
37º 48’ 19” N
002*
Treated Wastewater
37º 48’ 20” N
*Future outfall proposed as part of Facility expansion, anticipated 2015.
Discharge Point
Longitude
121º 24’ 07” W
121º 24’ 15” W
Receiving
Water
Old River
Old River
Table 3. Administrative Information
This Order was adopted by the Regional Water Quality Control Board on:
This Order shall become effective on:
This Order shall expire on:
The Discharger shall file a Report of Waste Discharge in accordance with title
23, California Code of Regulations, as application for issuance of new waste
discharge requirements no later than:
7 December 2012
26 January 2013
1 December 2017
3 June 2017
I, PAMELA C. CREEDON, Executive Officer, do hereby certify that this Order with all
attachments is a full, true, and correct copy of an Order adopted by the California Regional Water
Quality Control Board, Central Valley Region, on 7 December 2012.
ORIGINAL SIGNED BY
_______________________________________
PAMELA C. CREEDON, Executive Officer
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Table of Contents
I.
II.
III.
IV.
Facility Information ............................................................................................................. 3
Findings ............................................................................................................................. 3
Discharge Prohibitions ..................................................................................................... 12
Effluent Limitations and Discharge Specifications ........................................................... 12
A. Effluent Limitations – Discharge Point No. 001 and Discharge Point No. 002 .......... 12
B. Land Discharge Specifications – Set forth in WDR Order No. R5-2007-0038........... 15
C. Reclamation Specifications – Not Applicable ............................................................ 15
V. Receiving Water Limitations ............................................................................................ 15
A. Surface Water Limitations ......................................................................................... 15
B. Groundwater Limitations (Set forth in WDR Order No. R5-2007-0038)..................... 17
VI. Provisions ........................................................................................................................ 17
A. Standard Provisions .................................................................................................. 17
B. Monitoring and Reporting Program Requirements .................................................... 22
C. Special Provisions ..................................................................................................... 22
1. Reopener Provisions ............................................................................................. 22
2. Special Studies, Technical Reports and Additional Monitoring Requirements ...... 23
3. Best Management Practices and Pollution Prevention.......................................... 25
4. Construction, Operation and Maintenance Specifications ..................................... 27
5. Special Provisions for Municipal Facilities (POTWs Only) .................................... 27
6. Other Special Provisions ....................................................................................... 29
7. Compliance Schedules ......................................................................................... 31
VII. Compliance Determination............................................................................................... 32
List of Tables
Table 1.
Table 2.
Table 3.
Table 4.
Table 5.
Table 6.
Discharger Information .............................................................................................. 1
Discharge Location .................................................................................................... 1
Administrative Information ......................................................................................... 1
Facility Information..................................................................................................... 3
Basin Plan Beneficial Uses ........................................................................................ 6
Effluent Limitations ................................................................................................. 12
List of Attachments
Attachment A – Definitions...................................................................................................... A-1
Attachment B – Map ............................................................................................................... B-1
Attachment C – Flow Schematic ............................................................................................. B-1
Attachment D – Standard Provisions ..................................................................................... D-1
Attachment E – Monitoring and Reporting Program ............................................................... E-1
Attachment F – Fact Sheet ..................................................................................................... F-1
Attachment G – Summary of Reasonable Potential Analysis ................................................ G-1
Attachment H – Calculation of WQBELs ................................................................................ H-1
Attachment I – Effluent and Receiving Water Characterization Study ..................................... I-1
Attachment J – Dioxin and Furan Sampling ............................................................................ J-1
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I.
ORDER R5-2012-0115
NPDES NO. CA0079154
FACILITY INFORMATION
The following Discharger is subject to waste discharge requirements as set forth in this
Order:
Table 4. Facility Information
Discharger
Name of Facility
Facility Address
Facility Contact, Title, and Phone
Mailing Address
Type of Facility
Facility Design Flow
II.
City of Tracy
Tracy Wastewater Treatment Plant
3900 Holly Drive
Tracy, CA 95304
San Joaquin County
Mr. Steve Bayley, Deputy Director of Public Works (209) 831-4434
SAME
Publicly Owned Treatment Works
10.8 million gallons per day (mgd) (with expansion to 16 mgd)
FINDINGS
The California Regional Water Quality Control Board, Central Valley Region (hereinafter
Central Valley Water Board), finds:
A. Background. The City of Tracy (hereinafter Discharger) was authorized to discharge
pursuant to Order R5-2007-0036-01 and National Pollutant Discharge Elimination
System (NPDES) Permit No. CA0079154. The Discharger submitted a Report of Waste
Discharge (ROWD), dated 3 November 2011, and applied for a NPDES permit renewal
to discharge up to 16 million gallons per day (mgd) of tertiary treated wastewater from
the Tracy Wastewater Treatment Plant (hereinafter Facility) to the Old River, within the
Sacramento- San Joaquin Delta, a water of the United States. On 17 November 2011,
the Discharger was notified their application was incomplete and a letter was sent
requesting supplemental information. Subsequently, on 5 March 2012, the City of Tracy
submitted a modified ROWD and the application was deemed complete.
For the purposes of this Order, references to the “discharger” or “permittee” in applicable
federal and state laws, regulations, plans, or policy are held to be equivalent to
references to the Discharger herein.
B. Facility Description. The Discharger owns and operates a wastewater collection,
treatment, and disposal system. The treatment system consists of a main treatment
facility and an industrial pretreatment facility. The main treatment facility consists of raw
influent bar screening, primary sedimentation, flow equalization, biological nutrient
removal, secondary sedimentation, tertiary filtration, chlorination, dechlorination, and
post aeration. Biosolids are thickened by dissolved air flotation, anaerobically digested,
and dewatered in impermeable drying beds. The dried biosolids are hauled off-site for
land application or for disposal in a landfill. The industrial pretreatment facility consists
of four unlined industrial ponds. In addition, Leprino Foods Company (Leprino), a local
cheese manufacturer, leases two aerated lagoons and one unlined oxidation pond from
the Discharger for pretreatment of its industrial food processing wastewater. Per an
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NPDES NO. CA0079154
industrial pretreatment permit, the Discharger accepts pretreated industrial food
processing wastewater from Leprino. The industrial wastewater and other process
water from the main facility are stored in the unlined industrial ponds and returned to the
primary sedimentation basins of the main facility. Wastewater is discharged from
Discharge Point No. 001 (see table on cover page) to Old River, a water of the United
States and part of the Sacramento-San Joaquin Delta (Delta). Attachment B (Figure B1) provides a topographic map describing the location of the Facility. Attachment C
(Figures C-1 and C-2) provides wastewater flow schematics for the Facility.
This Order only regulates the surface water discharge to Old River. Separate Waste
Discharge Requirements (WDR) Order R5-2007-0038 regulates discharges to land at
the Facility.
The Discharger is upgrading the Facility to improve treatment and expand capacity. The
treatment system capacity will be expanded to 16 mgd through a four-phase expansion.
Phase 1 was completed in August 2008, which increased the treatment capacity from 9
mgd to 10.8 mgd and included nitrification, denitrification and tertiary filtration. The
proposed Phase 2 improvements will be completed during the term of this Order and will
include construction of a second outfall near the existing outfall and paving of additional
sludge drying beds. A detailed description of the planned changes are discussed in
Attachment F, Section II.E.
C. Legal Authorities. This Order is issued pursuant to section 402 of the Clean Water Act
(CWA) and implementing regulations adopted by USEPA and chapter 5.5, division 7 of
the California Water Code (Water Code; commencing with section 13370). It shall serve
as a NPDES permit for point source discharges from this facility to surface waters. This
Order also serves as Waste Discharge Requirements (WDRs) pursuant to article 4,
chapter 4, division 7 of the Water Code (commencing with section 13260).
D. Background and Rationale for Requirements. The Central Valley Water Board
developed the requirements in this Order based on information submitted as part of the
application, through monitoring and reporting programs, and other available information.
The Fact Sheet (Attachment F), which contains background information and rationale for
Order requirements, is hereby incorporated into this Order and constitutes part of the
Findings for this Order. Attachments A through E and G through J are also incorporated
into this Order.
E. California Environmental Quality Act (CEQA). Under Water Code section 13389, this
action to adopt an NPDES permit is exempt from the provisions of CEQA, Public
Resources Code sections 21100-21177.
F. Technology-based Effluent Limitations. Section 301(b) of the CWA and
implementing USEPA permit regulations at section 122.44, title 40 of the Code of
Federal Regulations (40 CFR 122.44), require that permits include conditions meeting
applicable technology-based requirements at a minimum, and any more stringent
effluent limitations necessary to meet applicable water quality standards. The discharge
authorized by this Order must meet minimum federal technology-based requirements
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based on Secondary Treatment Standards at 40 CFR Part 133. A detailed discussion of
the technology-based effluent limitations development is included in the Fact Sheet.
G. Water Quality-based Effluent Limitations (WQBELs). Section 301(b) of the CWA
and 40 CFR 122.44(d) require that permits include limitations more stringent than
applicable federal technology-based requirements where necessary to achieve
applicable water quality standards. This Order contains requirements, expressed as
technology equivalence requirements, which are necessary to achieve water quality
standards. The Central Valley Water Board has considered the factors listed in Water
Code section 13241 in establishing these requirements. The rationale for these
requirements, which consist of tertiary treatment or equivalent requirements, is
discussed in the Fact Sheet.
40 CFR 122.44(d)(1)(i) mandates that permits include effluent limitations for all
pollutants that are or may be discharged at levels that have the reasonable potential to
cause or contribute to an exceedance of a water quality standard, including numeric and
narrative objectives within a standard. Where reasonable potential has been
established for a pollutant, but there is no numeric criterion or objective for the pollutant,
WQBELs must be established using: (1) USEPA criteria guidance under CWA section
304(a), supplemented where necessary by other relevant information; (2) an indicator
parameter for the pollutant of concern; or (3) a calculated numeric water quality criterion,
such as a proposed state criterion or policy interpreting the state’s narrative criterion,
supplemented with other relevant information, as provided in 40 CFR 122.44(d)(1)(vi).
H. Water Quality Control Plans. The Central Valley Water Board adopted a Water
Quality Control Plan, Fourth Edition (Revised October 2011), for the Sacramento and
San Joaquin River Basins (hereinafter Basin Plan) that designates beneficial uses in
Section II, establishes water quality objectives, and contains implementation programs
and policies to achieve those objectives for all waters addressed through the plan.
Table II-1 of the Basin Plan identifies the beneficial uses of certain specific water bodies.
The Old River is listed in Table II-1. In addition, the Basin Plan implements State Water
Resources Control Board (State Water Board) Resolution No. 88-63, which established
state policy that all waters, with certain exceptions, should be considered suitable or
potentially suitable for municipal or domestic supply. Beneficial uses applicable to Old
River are as follows:
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Table 5. Basin Plan Beneficial Uses
Discharge
Point
Receiving Water
Name
001
Old River
002*
Old River
Beneficial Use(s)
Existing uses from Table II-1 of the Basin Plan:
Municipal and domestic supply (MUN);
agricultural supply and stock watering (AGR);
industrial process water supply (PROC),
industrial service supply (IND);
water contact recreation (REC-1);
other non-contact water recreation (REC-2);
warm freshwater aquatic habitat (WARM);
cold freshwater aquatic habitat (COLD);
warm and cold fish migration habitat (MIGR);
warm spawning habitat (SPAWN);
wildlife habitat (WILD);
commercial and sport fishing (COMM)
and navigation (NAV).
Potential uses from Table II-1 of the Basin Plan:
None
Intermittent uses from Section II of the Basin Plan:
None
Suitable uses from State Water Board Resolution No. 88-63:
Municipal and domestic supply (MUN).
Existing uses from Table II-1 of the Basin Plan:
Municipal and domestic supply (MUN);
agricultural supply and stock watering (AGR);
industrial process water supply (PROC),
industrial service supply (IND);
water contact recreation (REC-1);
other non-contact water recreation (REC-2);
warm freshwater aquatic habitat (WARM);
cold freshwater aquatic habitat (COLD);
warm and cold fish migration habitat (MIGR);
warm spawning habitat (SPAWN);
wildlife habitat (WILD);
commercial and sport fishing (COMM)
and navigation (NAV).
Potential uses from Table II-1 of the Basin Plan:
None
Intermittent uses from Section II of the Basin Plan:
None
Suitable uses from State Water Board Resolution No. 88-63:
Municipal and domestic supply (MUN).
*Future outfall proposed for Facility expansion, expected 2015.
The Basin Plan includes a list of Water Quality Limited Segments (WQLSs), which are
defined as “…those sections of lakes, streams, rivers or other fresh water bodies where
water quality does not meet (or is not expected to meet) water quality standards even
after the application of appropriate limitations for point sources (40 CFR 130, et seq.).”
The Basin Plan also states, “Additional treatment beyond minimum federal standards
will be imposed on dischargers to WQLSs. Dischargers will be assigned or allocated a
maximum allowable load of critical pollutants so that water quality objectives can be met
in the segment.” The listing for the western portion Sacramento-San Joaquin Delta
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waterways includes: diazinon and chlorpyrifos, organo-chlorine Group A pesticides,
DDT, mercury, electrical conductivity, and unknown toxicity. The listing for Old River
between the San Joaquin River and the Delta-Mendota Canal also includes dissolved
oxygen deficiencies. Effluent limitations for these constituents are included in this Order.
The Water Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin
Delta Estuary (Bay-Delta Plan) was adopted in December 2006 by the State Water
Board superseding the 1995 Bay-Delta Plan. The State Water Board is in the process
of a phased review and update of the Bay-Delta Plan. The Bay-Delta Plan identifies the
beneficial uses of the estuary and includes objectives for flow, salinity, and endangered
species protection.
The State Water Board adopted Decision 1641 (D-1641) on 29 December 1999, and
revised on 15 March 2000. D-1641 implements flow objectives for the Bay-Delta
Estuary, approves a petition to change points of diversion of the Central Valley Project
and the State Water Project in the Southern Delta, and approves a petition to change
places of use and purposes of use of the Central Valley Project. The water quality
objectives of the Bay-Delta Plan are implemented as part of this Order.
The Bay-Delta Plan includes water quality objectives for Electrical Conductivity (EC) for
the South Delta in the vicinity of the discharge1. On 1 June 2011, the Superior Court for
Sacramento County entered a judgment and peremptory writ of mandate in the matter of
City of Tracy v. State Water Resources Control Board (Case No; 34-2009-8000-392-CUWM-GDS), ruling that the South Delta salinity objectives shall not apply to the City of
Tracy and other municipal dischargers in the South Delta area pending reconsideration
of the South Delta salinity objectives under Water Code §13241 and adoption of a
proper program of implementation under Water Code §13242 that includes municipal
dischargers. The State Water Board is currently considering new salinity and flow
objectives in the South Delta that will address the Court Order. Therefore, at the time
this Order was adopted the South Delta salinity objectives were not applicable to the
Discharger.
Requirements of this Order specifically implement the applicable Water Quality Control
Plans.
I. National Toxics Rule (NTR) and California Toxics Rule (CTR). USEPA adopted the
NTR on 22 December 1992, and later amended it on 4 May 1995 and
9 November 1999. About 40 criteria in the NTR applied in California. On 18 May 2000,
USEPA adopted the CTR. The CTR promulgated new toxics criteria for California and,
in addition, incorporated the previously adopted NTR criteria that were applicable in the
state. The CTR was amended on 13 February 2001. These rules contain water quality
criteria for priority pollutants.
1
The Bay-Delta Plan includes water quality objectives at three locations in the South Delta for EC. The water
quality objectives are a 14-day running average EC of 700 µmhos/cm from 1 April – 31 Aug and a 14-day running
average EC of 1000 µmhos/cm from 1 September - 31 March.
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J. State Implementation Policy. On 2 March 2000, the State Water Board adopted the
Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed
Bays, and Estuaries of California (State Implementation Policy or SIP). The SIP
became effective on 28 April 2000 with respect to the priority pollutant criteria
promulgated for California by USEPA through the NTR and to the priority pollutant
objectives established by the Central Valley Water Board in the Basin Plan. The SIP
became effective on 18 May 2000 with respect to the priority pollutant criteria
promulgated by USEPA through the CTR. The State Water Board adopted
amendments to the SIP on 24 February 2005 that became effective on 13 July 2005.
The SIP establishes implementation provisions for priority pollutant criteria and
objectives and provisions for chronic toxicity control. Requirements of this Order
implement the SIP.
K. Compliance Schedules and Interim Requirements. In general, an NPDES permit
must include final effluent limitations that are consistent with CWA section 301 and with
40 CFR 122.44(d). There are exceptions to this general rule. The State Water Board’s
Policy for Compliance Schedules in National Pollutant Discharge Elimination System
Permits (Compliance Schedule Policy) allows compliance schedules for new, revised, or
newly interpreted water quality objectives or criteria, or in accordance with a TMDL. All
compliance schedules must be as short as possible, and may not exceed ten years from
the effective date of the adoption, revision, or new interpretation of the applicable water
quality objective or criterion, unless a TMDL allows a longer schedule. The Central
Valley Water Board, however, is not required to include a compliance schedule, but may
issue a Time Schedule Order pursuant to Water Code section 13300 or a Cease and
Desist Order pursuant to Water Code section 13301 where it finds that the discharger is
violating or threatening to violate the permit. The Central Valley Water Board will
consider the merits of each case in determining whether it is appropriate to include a
compliance schedule in a permit, and, consistent with the Compliance Schedule Policy,
should consider feasibility of achieving compliance, and must impose a schedule that is
as short as possible to achieve compliance with the effluent limit based on the objective
or criteria.
Where a compliance schedule for a final effluent limitation exceeds one year, the Order
must include interim numeric limitations for that constituent or parameter, interim
milestones and compliance reporting within 14 days after each interim milestone. The
permit may also include interim requirements to control the pollutant, such as pollutant
minimization and source control measures. This Order does include compliance
schedules and interim effluent limitations. A detailed discussion of the basis for the
compliance schedules and interim effluent limitation(s) is included in the Fact Sheet.
L. Alaska Rule. On 30 March 2000, USEPA revised its regulation that specifies when new
and revised state and tribal water quality standards become effective for CWA purposes.
(40 CFR 131.21 and 65 FR 24641 (27 April 2000).) Under the revised regulation (also
known as the Alaska rule), new and revised standards submitted to USEPA after
30 May 2000, must be approved by USEPA before being used for CWA purposes. The
final rule also provides that standards already in effect and submitted to USEPA by
30 May 2000 may be used for CWA purposes, whether or not approved by USEPA.
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M. Stringency of Requirements for Individual Pollutants. This Order contains both
technology-based effluent limitations and WQBELs for individual pollutants. The
technology-based effluent limitations consist of restrictions on pH, biochemical oxygen
demand (BOD), total suspended solids (TSS), and flow. The WQBELs consist of
restrictions on ammonia (total as N), bis(2-ethylhexyl) phthalate, copper (total
recoverable), chlorodibromomethane, dichlorobromomethane, BOD, TSS, pH, lead (total
recoverable), nitrate plus nitrite (total as N), temperature, total residual chlorine,
methylmercury, chlorpyrifos, diazinon, acute whole effluent toxicity, and chronic whole
effluent toxicity. This Order’s technology-based pollutant restrictions implement the
minimum, applicable federal technology-based requirements.
WQBELs have been scientifically derived to implement water quality objectives that
protect beneficial uses. Both the beneficial uses and the water quality objectives have
been approved pursuant to federal law and are the applicable federal water quality
standards. To the extent that toxic pollutant WQBELs were derived from the CTR, the
CTR is the applicable standard pursuant to 40 CFR 131.38. The scientific procedures
for calculating the individual WQBELs for priority pollutants are based on the CTR-SIP,
which was approved by USEPA on 18 May 2000. All beneficial uses and water quality
objectives contained in the Basin Plan were approved under state law and submitted to
and approved by USEPA prior to 30 May 2000. Any water quality objectives and
beneficial uses submitted to USEPA prior to 30 May 2000, but not approved by USEPA
before that date, are nonetheless “applicable water quality standards for purposes of the
[Clean Water] Act” pursuant to 40 CFR 131.21(c)(1). Collectively, this Order’s
restrictions on individual pollutants are no more stringent than required to implement the
technology-based requirements of the CWA and the applicable water quality standards
for purposes of the CWA.
N. Antidegradation Policy. 40 CFR 131.12 requires that the state water quality standards
include an antidegradation policy consistent with the federal policy. The State Water
Board established California’s antidegradation policy in State Water Board Resolution
No. 68-16. Resolution No. 68-16 incorporates the federal antidegradation policy where
the federal policy applies under federal law. Resolution No. 68-16 requires that existing
quality of waters be maintained unless degradation is justified based on specific
findings. The Central Valley Water Board’s Basin Plan implements, and incorporates by
reference, both the state and federal antidegradation policies. As discussed in detail in
the Fact Sheet, the permitted discharge is consistent with the antidegradation provision
of 40 CFR 131.12 and Resolution No. 68-16.
O. Anti-Backsliding Requirements. Sections 303(d)(4) and 402(o)(2) of the CWA and
federal regulations at 40 CFR 122.44(l) prohibit backsliding in NPDES permits. These
anti-backsliding provisions require effluent limitations in a reissued permit to be as
stringent as those in the previous permit, with some exceptions. Some effluent
limitations in this Order are less stringent that those in Order R5-2007-0036-01. As
discussed in detail in the Fact Sheet, this relaxation of effluent limitations is consistent
with the anti-backsliding requirements of the CWA and federal regulations.
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P. Endangered Species Act. This Order does not authorize any act that results in the
taking of a threatened or endangered species or any act that is now prohibited, or
becomes prohibited in the future, under either the California Endangered Species Act
(Fish and Game Code sections 2050 to 2097) or the Federal Endangered Species Act
(16 U.S.C.A. sections 1531 to 1544). This Order requires compliance with effluent
limits, receiving water limits, and other requirements to protect the beneficial uses of
waters of the state. The discharger is responsible for meeting all requirements of the
applicable Endangered Species Act.
Q. Monitoring and Reporting. 40 CFR 122.48 requires that all NPDES permits specify
requirements for recording and reporting monitoring results. Water Code sections
13267 and 13383 authorize the Central Valley Water Board to require technical and
monitoring reports. The Monitoring and Reporting Program establishes monitoring and
reporting requirements to implement federal and State requirements. The Monitoring
and Reporting Program is provided in Attachment E.
The technical and monitoring reports in this Order are required in accordance with Water
Code section 13267, which states the following in subsection (b)(1), “In conducting an
investigation specified in subdivision (a), the regional board may require that any person
who has discharged, discharges, or is suspected of having discharged or discharging, or
who proposes to discharge waste within its region, or any citizen or domiciliary, or
political agency or entity of this state who has discharged, discharges, or is suspected of
having discharged or discharging, or who proposes to discharge, waste outside of its
region that could affect the quality of waters within its region shall furnish, under penalty
of perjury, technical or monitoring program reports which the regional board requires.
The burden, including costs, of these reports shall bear a reasonable relationship to the
need for the report and the benefits to be obtained from the reports. In requiring those
reports, the regional board shall provide the person with a written explanation with
regard to the need for the reports, and shall identify the evidence that supports requiring
that person to provide the reports.”
The Discharger owns and operates the Facility subject to this Order. The monitoring
reports required by this Order are necessary to determine compliance with this Order.
The need for the monitoring reports is discussed in the Fact Sheet.
R. Standard and Special Provisions. Standard Provisions, which apply to all NPDES
permits in accordance with 40 CFR 122.41, and additional conditions applicable to
specified categories of permits in accordance with 40 CFR 122.42, are provided in
Attachment D. The discharger must comply with all standard provisions and with those
additional conditions that are applicable under 40 CFR 122.42. The Central Valley
Water Board has also included in this Order special provisions applicable to the
Discharger. Some special provisions require submittal of technical reports. All technical
reports are required in accordance with Water Code section 13267. The rationale for
the special provisions and need for technical reports required in this Order are provided
in the Fact Sheet.
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S. Notification of Interested Parties. The Central Valley Water Board has notified the
Discharger and interested agencies and persons of its intent to prescribe WDRs for the
discharge and has provided them with an opportunity to submit their written comments
and recommendations. Details of notification are provided in the Fact Sheet of this
Order.
T. Consideration of Public Comment. The Central Valley Water Board, in a public
meeting, heard and considered all comments pertaining to the discharge. Details of the
Public Hearing are provided in the Fact Sheet.
THEREFORE, IT IS HEREBY ORDERED, that WDR Order R5-2007-0036-01 and TSO R52007-0037-01 are rescinded upon the effective date of this Order except for enforcement
purposes, and, in order to meet the provisions contained in division 7 of the Water Code
(commencing with section 13000) and regulations adopted thereunder, and the provisions
of the federal CWA and regulations and guidelines adopted thereunder, the Discharger
shall comply with the requirements in this Order.
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III.
ORDER R5-2012-0115
NPDES NO. CA0079154
DISCHARGE PROHIBITIONS
A. Discharge of treated wastewater at a location or in a manner different from that
described in the Findings is prohibited.
B. The by-pass or overflow of wastes to surface waters is prohibited, except as allowed by
Federal Standard Provisions I.G. and I.H. (Attachment D).
C. Neither the discharge nor its treatment shall create a nuisance as defined in section
13050 of the Water Code.
D. The Discharger shall not allow pollutant-free wastewater to be discharged into the
treatment or disposal system in amounts that significantly diminish the system’s
capability to comply with this Order. Pollutant-free wastewater means rainfall,
groundwater, cooling waters, and condensates that are essentially free of pollutants.
This discharge prohibition does not prohibit the return of pollutant-free wastewater from
a desalination plant.
IV.
EFFLUENT LIMITATIONS AND DISCHARGE SPECIFICATIONS
A. Effluent Limitations – Discharge Point No. 001 and Discharge Point No. 002
1.
Final Effluent Limitations
a. The Discharger shall maintain compliance with the following effluent limitations at
Discharge Point No. 001 and/or Discharge Point No. 002, with compliance
measured at Monitoring Location EFF-001 as described in the Monitoring and
Reporting Program:
Table 6.
Effluent Limitations
Parameter
Units
mg/L
Biochemical Oxygen
Demand (BOD) (5-day @
20 Deg. C)
Total Suspended Solids
pH
Ammonia
1
lbs/day
2
lbs/day
3
lbs/day
4
lbs/day
mg/L
1
lbs/day
2
lbs/day
3
lbs/day
4
lbs/day
standard
units
mg/L
1
lbs/day
2
lbs/day
Limitations and Discharge Requirements
Effluent Limitations
Maximum
Instantaneous
Daily
Minimum
20
--
Average
Monthly
10
Average
Weekly
15
Instantaneous
Maximum
--
900
1000
1100
1300
10
900
1000
1100
1300
1400
1500
1700
2000
15
1400
1500
1700
2000
1800
2000
2300
2700
20
1800
2000
2300
2700
----------
----------
--
--
--
6.5
8.5
1.3
120
130
----
2.1
190
210
----
-----
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
Parameter
ORDER R5-2012-0115
NPDES NO. CA0079154
Units
3
lbs/day
4
lbs/day
Average
Monthly
150
170
12
Average
Weekly
----
Effluent Limitations
Maximum
Instantaneous
Daily
Minimum
240
-280
-49
--
Instantaneous
Maximum
----
Bis(2-ethylhexyl) phthalate
µg/L
Copper
µg/L
15
-10.4
--(total recoverable)
Chlorodibromomethane
µg/L
8.0
-18
--Dichlorobromomethane
µg/L
11
-23
--Nitrate + Nitrite
mg/L
10
----(as N)
1
Based on an existing permitted flow of 10.8 mgd. Mass limits effective immediately and until compliance with
Special Provisions VI.C.6.a.
2
Based on a permitted flow of 12 mgd. Mass limits effective upon compliance with Special Provisions VI.C.6.b and
until compliance with Special Provisions VI.C.6.c.
3
Based on a permitted flow of 13.6 mgd. Mass limits effective upon compliance with Special Provisions VI.C.6.c
and until compliance with Special Provisions VI.C.6.d.
4
Based on a permitted flow of 16 mgd. Mass limits effective upon compliance with Special Provisions VI.C.6.d.
b. Percent Removal. The average monthly percent removal of 5-day biochemical
oxygen demand (BOD5) and total suspended solids (TSS) shall not be less than
85 percent.
c. Acute Whole Effluent Toxicity. Survival of aquatic organisms in 96-hour
bioassays of undiluted waste shall be no less than:
i.
ii.
70%, minimum for any one bioassay; and
90%, median for any three consecutive bioassays.
d. Temperature. The maximum temperature of the discharge shall not exceed the
natural receiving water temperature by more than 20°F.
e. Total Residual Chlorine. Effluent total residual chlorine shall not exceed:
i.
ii.
0.011 mg/L, as a 4-day average; and
0.019 mg/L, as a 1-hour average.
f. Total Dissolved Solids. The effluent total calendar annual mass loading of total
dissolved solids shall not exceed 13,688 tons.
g. Chronic Whole Effluent Toxicity. There shall be no chronic toxicity in the
effluent discharge.
h. Total Coliform Organisms. Effluent total coliform organisms shall not exceed:
2.2 most probable number (MPN) per 100 mL, as a 7-day median;
23 MPN/100 mL, more than once in any 30-day period; and
240 MPN/10 mL, at any time.
Limitations and Discharge Requirements
13
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
i. Methylmercury. The effluent calendar annual methylmercury load shall not
exceed 0.77 grams, in accordance with the Delta Mercury Control Program.
j. Average Dry Weather Flow.
i.
Effective immediately and until compliance with Special Provisions VI.C.6.a.,
the average dry weather flow shall not exceed 10.8 mgd.
ii.
Effective upon compliance with Special Provisions VI.C.6.a and until
compliance with Special Provisions VI.C.6.b., the average dry weather flow
shall not exceed 12 mgd.
iii.
Effective upon compliance with Special Provisions VI.C.6.b and until
compliance with Special Provisions VI.C.6.c., the average dry weather flow
shall not exceed 13.6 mgd.
iv.
Effective upon compliance with Special Provisions VI.C.6.d., the average dry
weather flow shall not exceed 16 mgd.
k. Chlorpyrifos and Diazinon. Effluent chlorpyrifos and diazinon concentrations
shall not exceed the sum of one as defined below:
i. Average Monthly Effluent Limit
SAMEL =
CD-avg
0.08
+
CC-avg
0.012
< 1.0
CD-avg = average monthly diazinon effluent concentration in μg/L
CC-avg = average monthly chlorpyrifos effluent concentration in μg/L
ii. Maximum Daily Effluent Limit
SMDEL =
CD-max
0.16
+
CC-max
0.025
< 1.0
CD-max = maximum daily diazinon effluent concentration in μg/L
CC-max = maximum daily chlorpyrifos effluent concentration in μg/L
2. Interim Effluent Limitations
The Discharger shall maintain compliance with the following interim effluent
limitations at Discharge Point No. 001 and/or Discharge Point No. 002, with
compliance measured at Monitoring Location EFF-001 as described in the
Monitoring and Reporting Program:
a. Mercury, Total. Effective immediately, and until 31 December 2030, the
effluent calendar year annual total mercury load shall not exceed 41 grams.
These interim effluent limitations shall apply in lieu of the final effluent limits for
methylmercury (Section IV.A.1.i).
Limitations and Discharge Requirements
14
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
B. Land Discharge Specifications – Set forth in WDR Order R5-2007-0038
C. Reclamation Specifications – Not Applicable
V.
RECEIVING WATER LIMITATIONS
A. Surface Water Limitations
Receiving water limitations are based on water quality objectives contained in the Basin
Plan and are a required part of this Order. The discharge shall not cause the following
in Old River:
1. Bacteria. The fecal coliform concentration, based on a minimum of not less than
five samples for any 30-day period, to exceed a geometric mean of
200 MPN/100 mL, nor more than 10 percent of the total number of fecal coliform
samples taken during any 30-day period to exceed 400 MPN/100 mL.
2. Biostimulatory Substances. Water to contain biostimulatory substances which
promote aquatic growths in concentrations that cause nuisance or adversely affect
beneficial uses.
3. Chemical Constituents. Chemical constituents to be present in concentrations that
adversely affect beneficial uses.
4. Color. Discoloration that causes nuisance or adversely affects beneficial uses.
5. Dissolved Oxygen: The dissolved oxygen concentration to be reduced below
5 mg/L.
6. Floating Material. Floating material to be present in amounts that cause nuisance
or adversely affect beneficial uses.
7. Oil and Grease. Oils, greases, waxes, or other materials to be present in
concentrations that cause nuisance, result in a visible film or coating on the surface
of the water or on objects in the water, or otherwise adversely affect beneficial uses.
8. pH. The pH to be depressed below 6.5 nor raised above 8.5.
9. Pesticides:
a. Pesticides to be present, individually or in combination, in concentrations that
adversely affect beneficial uses;
b. Pesticides to be present in bottom sediments or aquatic life in concentrations that
adversely affect beneficial uses;
Limitations and Discharge Requirements
15
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
c. Total identifiable persistent chlorinated hydrocarbon pesticides to be present in
the water column at concentrations detectable within the accuracy of analytical
methods approved by USEPA or the Executive Officer;
d. Pesticide concentrations to exceed those allowable by applicable antidegradation
policies (see State Water Board Resolution No. 68-16 and 40 CFR 131.12.);
e. Pesticide concentrations to exceed the lowest levels technically and economically
achievable;
f. Pesticides to be present in concentration in excess of the maximum contaminant
levels set forth in CCR, Title 22, division 4, chapter 15; nor
g. Thiobencarb to be present in excess of 1.0 µg/L.
10. Radioactivity:
a. Radionuclides to be present in concentrations that are harmful to human, plant,
animal, or aquatic life nor that result in the accumulation of radionuclides in the
food web to an extent that presents a hazard to human, plant, animal, or aquatic
life.
b. Radionuclides to be present in excess of the maximum contaminant levels
(MCLs) specified in Table 64442 of section 64442 and Table 64443 of section
64443 of Title 22 of the California Code of Regulations.
12. Suspended Sediments. The suspended sediment load and suspended sediment
discharge rate of surface waters to be altered in such a manner as to cause
nuisance or adversely affect beneficial uses.
13. Settleable Substances. Substances to be present in concentrations that result in
the deposition of material that causes nuisance or adversely affects beneficial uses.
14. Suspended Material. Suspended material to be present in concentrations that
cause nuisance or adversely affect beneficial uses.
15. Taste and Odors. Taste- or odor-producing substances to be present in
concentrations that impart undesirable tastes or odors to fish flesh or other edible
products of aquatic origin, or that cause nuisance, or otherwise adversely affect
beneficial uses.
Limitations and Discharge Requirements
16
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
16. Temperature.
a. The creation of a zone, defined by water temperatures of more than 1oF above
natural receiving water temperature, which exceeds 25 percent of the crosssectional area of the river channel at any point.
b. A surface water temperature rise greater than 4oF above the natural temperature
of the receiving water at any time or place.
17. Toxicity. Toxic substances to be present, individually or in combination, in
concentrations that produce detrimental physiological responses in human, plant,
animal, or aquatic life.
18. Turbidity.
a. Shall not exceed 2 Nephelometric Turbidity Units (NTU) where natural turbidity is
less than 1 NTU;
b. Shall not increase more than 1 NTU where natural turbidity is between 1 and
5 NTUs;
c. Shall not increase more than 20 percent where natural turbidity is between 5 and
50 NTUs;
d. Shall not increase more than 10 NTU where natural turbidity is between 50 and
100 NTUs; nor
e. Shall not increase more than 10 percent where natural turbidity is greater than
100 NTUs.
B. Groundwater Limitations (Set forth in WDR Order R5-2007-0038)
VI.
PROVISIONS
A. Standard Provisions
1. The Discharger shall comply with all Standard Provisions (federal NPDES standard
conditions from 40 CFR Part 122) included in Attachment D of this Order.
2. The Discharger shall comply with the following provisions:
a. If the Discharger’s wastewater treatment plant is publicly owned or subject to
regulation by California Public Utilities Commission, it shall be supervised and
operated by persons possessing certificates of appropriate grade according to
Title 23, CCR, division 3, chapter 26.
b. After notice and opportunity for a hearing, this Order may be terminated or
modified for cause, including, but not limited to:
Limitations and Discharge Requirements
17
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
violation of any term or condition contained in this Order;
obtaining this Order by misrepresentation or by failing to disclose fully all relevant
facts;
a change in any condition that requires either a temporary or permanent
reduction or elimination of the authorized discharge; and
a material change in the character, location, or volume of discharge.
The causes for modification include:

New regulations. New regulations have been promulgated under section
405(d) of the CWA, or the standards or regulations on which the permit was
based have been changed by promulgation of amended standards or
regulations or by judicial decision after the permit was issued.

Land application plans. When required by a permit condition to incorporate
a land application plan for beneficial reuse of sewage sludge, to revise an
existing land application plan, or to add a land application plan.

Change in sludge use or disposal practice. Under 40 CFR 122.62(a)(1), a
change in the Discharger’s sludge use or disposal practice is a cause for
modification of the permit. It is cause for revocation and reissuance if the
Discharger requests or agrees.
The Central Valley Water Board may review and revise this Order at any time
upon application of any affected person or the Central Valley Water Board's own
motion.
c. If a toxic effluent standard or prohibition (including any scheduled compliance
specified in such effluent standard or prohibition) is established under section
307(a) of the CWA, or amendments thereto, for a toxic pollutant that is present in
the discharge authorized herein, and such standard or prohibition is more
stringent than any limitation upon such pollutant in this Order, the Central Valley
Water Board will revise or modify this Order in accordance with such toxic effluent
standard or prohibition.
The Discharger shall comply with effluent standards and prohibitions within the
time provided in the regulations that establish those standards or prohibitions,
even if this Order has not yet been modified.
d. This Order shall be modified, or alternately revoked and reissued, to comply with
any applicable effluent standard or limitation issued or approved under sections
301(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) of the CWA, if the effluent
standard or limitation so issued or approved:
Limitations and Discharge Requirements
18
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
i.
Contains different conditions or is otherwise more stringent than any effluent
limitation in the Order; or
ii.
Controls any pollutant limited in the Order.
The Order, as modified or reissued under this paragraph, shall also contain any
other requirements of the CWA then applicable.
e. The provisions of this Order are severable. If any provision of this Order is found
invalid, the remainder of this Order shall not be affected.
f. The Discharger shall take all reasonable steps to minimize any adverse effects to
waters of the State or users of those waters resulting from any discharge or
sludge use or disposal in violation of this Order. Reasonable steps shall include
such accelerated or additional monitoring as necessary to determine the nature
and impact of the non-complying discharge or sludge use or disposal.
g. The Discharger shall ensure compliance with any existing or future pretreatment
standard promulgated by USEPA under section 307 of the CWA, or amendment
thereto, for any discharge to the municipal system.
h. A copy of this Order shall be maintained at the discharge facility and be available
at all times to operating personnel. Key operating personnel shall be familiar with
its content.
i. Safeguard to electric power failure:
i. The Discharger shall provide safeguards to assure that, should there be
reduction, loss, or failure of electric power, the discharge shall comply with the
terms and conditions of this Order.
ii. Upon written request by the Central Valley Water Board, the Discharger shall
submit a written description of safeguards. Such safeguards may include
alternate power sources, standby generators, retention capacity, operating
procedures, or other means. A description of the safeguards provided shall
include an analysis of the frequency, duration, and impact of power failures
experienced over the past 5 years on effluent quality and on the capability of
the Discharger to comply with the terms and conditions of the Order. The
adequacy of the safeguards is subject to the approval of the Central Valley
Water Board.
iii. Should the treatment works not include safeguards against reduction, loss, or
failure of electric power, or should the Central Valley Water Board not approve
the existing safeguards, the Discharger shall, within 90 days of having been
advised in writing by the Central Valley Water Board that the existing
safeguards are inadequate, provide to the Central Valley Water Board and
USEPA a schedule of compliance for providing safeguards such that in the
event of reduction, loss, or failure of electric power, the Discharger shall
Limitations and Discharge Requirements
19
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
comply with the terms and conditions of this Order. The schedule of
compliance shall, upon approval of the Central Valley Water Board, become a
condition of this Order.
j. The Discharger, upon written request of the Central Valley Water Board, shall file
with the Board a technical report on its preventive (failsafe) and contingency
(cleanup) plans for controlling accidental discharges, and for minimizing the effect
of such events. This report may be combined with that required under the Central
Valley Water Board Standard Provision contained in section VI.A.2.i of this Order.
The technical report shall:
i. Identify the possible sources of spills, leaks, untreated waste by-pass, and
contaminated drainage. Loading and storage areas, power outage, waste
treatment unit outage, and failure of process equipment, tanks and pipes
should be considered.
ii. Evaluate the effectiveness of present facilities and procedures and state when
they became operational.
iii. Predict the effectiveness of the proposed facilities and procedures and
provide an implementation schedule containing interim and final dates when
they will be constructed, implemented, or operational.
The Central Valley Water Board, after review of the technical report, may
establish conditions which it deems necessary to control accidental discharges
and to minimize the effects of such events. Such conditions shall be incorporated
as part of this Order, upon notice to the Discharger.
k. A publicly owned treatment works whose waste flow has been increasing, or is
projected to increase, shall estimate when flows will reach hydraulic and
treatment capacities of its treatment and disposal facilities. The projections shall
be made in January, based on the last 3 years' average dry weather flows, peak
wet weather flows and total annual flows, as appropriate. When any projection
shows that capacity of any part of the facilities may be exceeded in 4 years, the
Discharger shall notify the Central Valley Water Board by 31 January. A copy of
the notification shall be sent to appropriate local elected officials, local permitting
agencies and the press. Within 120 days of the notification, the Discharger shall
submit a technical report showing how it will prevent flow volumes from
exceeding capacity or how it will increase capacity to handle the larger flows.
The Central Valley Water Board may extend the time for submitting the report.
l. The Discharger shall submit technical reports as directed by the Executive
Officer. All technical reports required herein that involve planning, investigation,
evaluation, or design, or other work requiring interpretation and proper application
Limitations and Discharge Requirements
20
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
of engineering or geologic sciences, shall be prepared by or under the direction of
persons registered to practice in California pursuant to California Business and
Professions Code, sections 6735, 7835, and 7835.1. To demonstrate compliance
with Title 16, CCR, sections 415 and 3065, all technical reports must contain a
statement of the qualifications of the responsible registered professional(s). As
required by these laws, completed technical reports must bear the signature(s)
and seal(s) of the registered professional(s) in a manner such that all work can be
clearly attributed to the professional responsible for the work.
m. The Central Valley Water Board is authorized to enforce the terms of this permit
under several provisions of the Water Code, including, but not limited to, sections
13385, 13386, and 13387.
n. For publicly owned treatment works, prior to making any change in the point of
discharge, place of use, or purpose of use of treated wastewater that results in a
permanent decrease of flow in any portion of a watercourse, the Discharger must
file a petition with the State Water Board, Division of Water Rights, and receive
approval for such a change. (Water Code section 1211).
o. In the event the Discharger does not comply or will be unable to comply for any
reason, with any prohibition, maximum daily effluent limitation, 1-hour average or
instantaneous effluent limitation, or receiving water limitation contained in this
Order, the Discharger shall notify the Central Valley Water Board by telephone
(916) 464-3291 within 24 hours of having knowledge of such noncompliance, and
shall confirm this notification in writing within 5 days, unless the Central Valley
Water Board waives confirmation. The written notification shall include the
information required by the Standard Provision contained in Attachment D section
V.E.1. [40 CFR 122.41(l)(6)(i)].
p. Failure to comply with provisions or requirements of this Order, or violation of
other applicable laws or regulations governing discharges from this facility, may
subject the Discharger to administrative or civil liabilities, criminal penalties,
and/or other enforcement remedies to ensure compliance. Additionally, certain
violations may subject the Discharger to civil or criminal enforcement from
appropriate local, state, or federal law enforcement entities.
q. In the event of any change in control or ownership of land or waste discharge
facilities presently owned or controlled by the Discharger, the Discharger shall
notify the succeeding owner or operator of the existence of this Order by letter, a
copy of which shall be immediately forwarded to the Central Valley Water Board.
To assume operation under this Order, the succeeding owner or operator must
apply in writing to the Executive Officer requesting transfer of the Order. The
request must contain the requesting entity's full legal name, the state of
incorporation if a corporation, address and telephone number of the persons
responsible for contact with the Central Valley Water Board and a statement.
The statement shall comply with the signatory and certification requirements in
the federal Standard Provisions (Attachment D, section V.B) and state that the
Limitations and Discharge Requirements
21
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
new owner or operator assumes full responsibility for compliance with this Order.
Failure to submit the request shall be considered a discharge without
requirements, a violation of the Water Code. Transfer shall be approved or
disapproved in writing by the Executive Officer.
B. Monitoring and Reporting Program Requirements
The Discharger shall comply with the Monitoring and Reporting Program, and future
revisions thereto, in Attachment E of this Order.
C. Special Provisions
1. Reopener Provisions
a. Conditions that necessitate a major modification of a permit are described in
40 CFR 122.62, including, but not limited to:
i. If new or amended applicable water quality standards are promulgated or
approved pursuant to section 303 of the CWA, or amendments thereto, this
permit may be reopened and modified in accordance with the new or amended
standards.
ii. When new information, that was not available at the time of permit issuance,
would have justified different permit conditions at the time of issuance.
b. This Order may be reopened for modification, or revocation and reissuance, as a
result of the detection of a reportable priority pollutant generated by special
conditions included in this Order. These special conditions may be, but are not
limited to, fish tissue sampling, whole effluent toxicity, monitoring requirements on
internal waste stream(s), and monitoring for surrogate parameters. Additional
requirements may be included in this Order as a result of the special condition
monitoring data.
c. Mercury. The Basin Plan’s Delta Mercury Control Program was designed to
proceed in two phases. After Phase 1, the Central Valley Water Board will conduct
a Phase 1 Delta Mercury Control Program Review that considers: modification to
the Delta Mercury Control Program. This Order may be reopened to address
changes to the Delta Mercury Control Program.
d. Bay-Delta Plan South Delta Salinity Objectives Update. The State Water Board
is currently in the process of updating the South Delta Salinity Objectives contained
in the Bay-Delta Plan. The updated salinity objectives may result in needed
changes to the salinity requirements in this Order. Therefore, this Order may be
reopened to modify salinity requirements, as appropriate, in accordance with
changes to the Bay-Delta Plan.
e. Pollution Prevention. This Order requires the Discharger prepare pollution
prevention plans following Water Code section 13263.3(d)(3) for salinity and
mercury. Based on a review of the pollution prevention plans, this Order may be
Limitations and Discharge Requirements
22
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
reopened for addition and/or modification of effluent limitations and requirements
for these constituents.
f. Whole Effluent Toxicity. As a result of a Toxicity Reduction Evaluation (TRE), this
Order may be reopened to include a numeric chronic toxicity limitation, a new acute
toxicity limitation, and/or a limitation for a specific toxicant identified in the TRE.
Additionally, if the State Water Board revises the SIP’s toxicity control provisions,
this Order may be reopened to be consistent with the new provisions.
g. Water Effects Ratios (WER) and Metal Translators. A default WER of 1.0 and
default metal translators have been used in this Order for calculating CTR criteria
for applicable priority pollutant inorganic constituents. If the Discharger performs
studies to determine site-specific WERs and/or site-specific dissolved-to-total metal
translators, this Order may be reopened to modify the effluent limitations for the
applicable inorganic constituents.
h. Regional Monitoring Program. The Central Valley Water Board is developing a
Regional Monitoring Program for the Sacrament-San Joaquin Delta. This Order
may be reopened to modify the monitoring requirements to implement the Regional
Monitoring Program.
i. Drinking Water Policy. The Central Valley Water Board is developing a Drinking
Water Policy. This Order may be reopened to incorporate monitoring of drinking
water constituents to implement the Drinking Water Policy.
2. Special Studies, Technical Reports and Additional Monitoring Requirements
a. Chronic Whole Effluent Toxicity. For compliance with the Basin Plan’s
narrative toxicity objective, this Order requires the Discharger to conduct chronic
whole effluent toxicity (WET) testing, as specified in the Monitoring and Reporting
Program (Attachment E, section V). Furthermore, this Provision requires the
Discharger to investigate the causes of, and identify corrective actions to reduce
or eliminate effluent toxicity. If the discharge exhibits toxicity, as described in
subsection ii below, the Discharger is required to initiate a TRE in accordance
with an approved TRE Workplan, and take actions to mitigate the impact of the
discharge and prevent recurrence of toxicity. A TRE is a site-specific study
conducted in a stepwise process to identify the source(s) of toxicity and the
effective control measures for effluent toxicity. TREs are designed to identify the
causative agents and sources of effluent toxicity, evaluate the effectiveness of the
toxicity control options, and confirm the reduction in effluent toxicity. This
Provision includes procedures for accelerated chronic toxicity monitoring and
TRE initiation.
i.
Accelerated Monitoring and TRE Initiation. When the numeric toxicity
monitoring trigger is exceeded during regular chronic toxicity monitoring, the
Discharger shall initiate accelerated monitoring as required in the
Accelerated Monitoring Specifications. The Discharger shall initiate a TRE
Limitations and Discharge Requirements
23
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
to address effluent toxicity if any WET testing results exceed the numeric
toxicity monitoring trigger during accelerated monitoring.
ii.
Numeric Toxicity Monitoring Trigger. The numeric toxicity monitoring
trigger to initiate a TRE is > 1 TUC (where TUC = 100/NOEC). The
monitoring trigger is not an effluent limitation; it is the toxicity threshold at
which the Discharger is required to begin accelerated monitoring and initiate
a TRE when the effluent exhibits toxicity.
iii.
Accelerated Monitoring Specifications. If the numeric toxicity monitoring
trigger is exceeded during regular chronic toxicity testing, the Discharger
shall initiate accelerated monitoring within 14 days of notification by the
laboratory of the exceedance. Accelerated monitoring shall consist of four
(4) chronic toxicity tests conducted once every 2 weeks using the species
that exhibited toxicity. The following protocol shall be used for accelerated
monitoring and TRE initiation:
(a) If the results of four (4) consecutive accelerated monitoring tests do not
exceed the monitoring trigger, the Discharger may cease accelerated
monitoring and resume regular chronic toxicity monitoring. However,
notwithstanding the accelerated monitoring results, if there is evidence of
effluent toxicity, the Executive Officer may require that the Discharger
initiate a TRE.
(b) If the source(s) of the toxicity is easily identified (e.g., temporary plant
upset), the Discharger shall make necessary corrections to the facility
and shall continue accelerated monitoring until four (4) consecutive
accelerated tests do not exceed the monitoring trigger. Upon
confirmation that the effluent toxicity has been removed, the Discharger
may cease accelerated monitoring and resume regular chronic toxicity
monitoring.
(c) If the result of any accelerated toxicity test exceeds the monitoring
trigger, the Discharger shall cease accelerated monitoring and begin a
TRE to investigate the cause(s) of, and identify corrective actions to
reduce or eliminate effluent toxicity. Within thirty (30) days of notification
by the laboratory of any test result exceeding the monitoring trigger
during accelerated monitoring, the Discharger shall submit a TRE Action
Plan to the Central Valley Water Board including, at minimum:
(1) Specific actions the Discharger will take to investigate and identify the
cause(s) of toxicity, including a TRE WET monitoring schedule;
(2) Specific actions the Discharger will take to mitigate the impact of the
discharge and prevent the recurrence of toxicity; and
(3) A schedule for these actions.
Limitations and Discharge Requirements
24
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
b. Phase 1 Methylmercury Control Study. In accordance with the Basin Plan’s
Delta Mercury Control Program and the compliance schedule included in this
Order for methylmercury (Section VI.C.7.a), the Discharger shall participate in the
Central Valley Clean Water Association (CVCWA) Coordinated Methylmercury
Control Study (Study) to evaluate existing control methods and, as needed,
develop additional control methods that could be implemented to achieve the
methylmercury waste load allocation. A work plan shall be submitted by 20 April
2013. The study work plan will be reviewed by a Technical Advisory Committee
(TAC) and approved by the Executive Officer. The work plan shall be
implemented immediately after approval by the Executive Officer, and a progress
report shall be submitted by 20 October 2015.
The Study shall evaluate the feasibility of reducing sources more than the
minimum amount needed to achieve the methylmercury allocation. The Study
also may include an evaluation of innovative actions, watershed approaches,
offsets projects, and other short and long-term actions that result in reducing
inorganic (total) mercury and methylmercury to address the accumulation of
methylmercury in fish tissue and to reduce methylmercury exposure. The Study
may evaluate the effectiveness of using inorganic (total) mercury controls to
control methylmercury discharges.
The Study shall include a description of methylmercury and/or inorganic (total)
mercury management practices identified in Phase 1; an evaluation of the
effectiveness, costs, potential environmental effects, and overall feasibility of the
control actions. The Study shall also include proposed implementation plans and
schedules to comply with methylmercury allocations as soon as possible. The
Study shall be submitted to the Central Valley Water Board by 20 October 2018.
The Executive Officer may, after public notice, extend the due date up to two
years if the Discharger demonstrates it is making significant progress towards
developing, implementing and/or completing the Study and reasonable attempts
have been made to secure funding for the Study, but the Discharger has
experienced severe budget shortfalls.
3. Best Management Practices and Pollution Prevention
a. Pollution Prevention Plan for Mercury. The Discharger shall update and
implement a pollution prevention plan (PPP) for mercury in accordance with
Water Code section 13263.3(d)(3), per the compliance schedule in this Order for
methylmercury (Section VI.C.7.a). The minimum requirements for the pollution
prevention plan are outlined in the Fact Sheet (Attachment F section VII.B.3.c).
Progress reports shall be submitted annually in accordance with the Monitoring
and Reporting Program (Attachment E section X.D.1.). The progress reports
shall discuss the effectiveness of the PPP in the reduction of mercury in the
discharge, include a summary of mercury and methylmercury monitoring results,
and discuss updates to the PPP.
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b. Mercury Exposure Reduction Program. The Discharger shall participate in a
mercury Exposure Reduction Program in accordance with the Basin Plan’s Delta
Mercury Control Program. The Discharger, either individually or collectively with
other Delta dischargers, shall submit an exposure reduction work plan for
Executive Officer approval by 20 October 2013. The objective of the Exposure
Reduction Program is to reduce mercury exposure of Delta fish consumers most
likely affected by mercury. The work plan shall address the Exposure Reduction
Program objective, elements, and the Discharger’s coordination with other
stakeholders. The minimum requirements for the exposure reduction work plan
are outlined in the Fact Sheet (Attachment F section VII.B.3.b). The Discharger
shall integrate or, at minimum, provide good-faith opportunities for integration of
community-based organizations, tribes, and consumers of Delta fish into
planning, decision making, and implementation of exposure reduction activities.
The Discharger shall implement the work plan within six months of
Executive Officer approval.
c. Salinity Reduction Plan. The Discharger shall maintain the Salinity Reduction
Plan, submitted on 30 June 2008, that describes the Discharger’s approach to
identify, evaluate, and implement measures to reduce salinity in the effluent
discharge to Old River. The Discharger shall submit annual progress reports in
accordance the Monitoring and Reporting Program (Attachment E section
X.D.1.). The Salinity Reduction Plan shall, at minimum, contain the following:
i.
Pollution Prevention Plan (PPP). The Discharger submitted a PPP for
salinity that meets the requirements of Water Code section 13263.3(d)(3).
The Discharger shall continue to implement the PPP and evaluate and
update the PPP annually. The annual progress reports for the Salinity
Reduction Plan shall include a discussion of the effectiveness of the PPP
and any updates to the PPP.
ii.
Salinity Reduction Goal. The Central Valley Water Board finds that a
calendar annual average of 500 µmhos/cm as electrical conductivity
increase over the calendar annual weighted average electrical conductivity
of the City of Tracy’s water supply is a reasonable increase due to
consumptive use in the community. The annual progress reports for the
Salinity Reduction Plan shall include a discussion of the progress in meeting
the salinity reduction goal.
iii.
Best Practicable Treatment or Control (BPTC) Evaluation for Salinity.
The Discharger submitted a BPTC evaluation dated 13 September 2011.
By 1 September 2016, the Discharger shall update and submit a BPTC
evaluation for salinity that considers new information that was not available
at the time the September 2011 BPTC evaluation was developed.
iv.
Central Valley Salinity Alternatives for Long-Term Sustainability
(CV-SALTS) Participation. The Discharger shall participate in CV-SALTS.
The annual progress reports for the Salinity Reduction Plan shall include a
discussion of the Discharger’s participation in CV-SALTS.
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v.
ORDER R5-2012-0115
NPDES NO. CA0079154
Lower Salinity Water Supply Sources. The Salinity Reduction Plan shall
include a discussion of the Discharger’s efforts to obtain lower salinity water
supplies and the annual progress reports for the Salinity Reduction Plan
shall include a discussion of the Discharger’s efforts in this area.
4. Construction, Operation and Maintenance Specifications
a. Turbidity. The Discharger shall operate the treatment system to ensure that the
turbidity measured at EFF-001, as described in the MRP (Attachment E), shall
not exceed:
2 NTU, as a daily average;
5 NTU, more than 5% of the time within a 24-hour period;
10 NTU, at any time.
5. Special Provisions for Municipal Facilities (POTWs Only)
a. Pretreatment Requirements.
i.
The Discharger shall be responsible and liable for the performance of all
Control Authority pretreatment requirements contained in 40 CFR Part 403,
including any subsequent regulatory revisions to 40 CFR Part 403. Where
40 CFR Part 403 or subsequent revision places mandatory actions upon the
Discharger as Control Authority but does not specify a timetable for
completion of the actions, the Discharger shall complete the required actions
within 6 months from the issuance date of this permit or the effective date of
the 40 CFR Part 403 revisions, whichever comes later. For violations of
pretreatment requirements, the Discharger shall be subject to enforcement
actions, penalties, fines, and other remedies by USEPA or other appropriate
parties, as provided in the CWA.
ii.
The Discharger shall enforce the requirements promulgated under sections
307(b), 307(c), 307(d), and 402(b) of the CWA with timely, appropriate and
effective enforcement actions. The Discharger shall cause all nondomestic
users subject to federal categorical standards to achieve compliance no
later than the date specified in those requirements or, in the case of a new
nondomestic user, upon commencement of the discharge.
iii.
The Discharger shall perform the pretreatment functions as required in
40 CFR Part 403 including, but not limited to:
(a) Implement the necessary legal authorities as provided in
40 CFR 403.8(f)(1);
(b) Enforce the pretreatment requirements under 40 CFR 403.5 and 403.6;
(c) Implement the programmatic functions as provided in
40 CFR 403.8(f)(2); and
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CITY OF TRACY
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ORDER R5-2012-0115
NPDES NO. CA0079154
(d) Provide the requisite funding and personnel to implement the
pretreatment program as provided in 40 CFR 403.8(f)(3).
iv.
The Discharger shall implement, as more completely set forth in
40 CFR 403.5, the necessary legal authorities, programs, and controls to
ensure that the following incompatible wastes are not introduced to the
treatment system, where incompatible wastes are:
(a) Wastes which create a fire or explosion hazard in the treatment works;
(b) Wastes which will cause corrosive structural damage to treatment works,
but in no case wastes with a pH lower than 5.0, unless the works is
specially designed to accommodate such wastes;
(c) Solid or viscous wastes in amounts which cause obstruction to flow in
sewers, or which cause other interference with proper operation or
treatment works;
(d) Any waste, including oxygen demanding pollutants (BOD, etc.), released
in such volume or strength as to cause inhibition or disruption in the
treatment works, and subsequent treatment process upset and loss of
treatment efficiency;
(e) Heat in amounts that inhibit or disrupt biological activity in the treatment
works, or that raise influent temperatures above 40°C (104°F), unless the
Central Valley Water Board approves alternate temperature limits;
(f) Petroleum oil, non-biodegradable cutting oil, or products of mineral oil
origin in amounts that will cause interference or pass through;
(g) Pollutants which result in the presence of toxic gases, vapors, or fumes
within the treatment works in a quantity that may cause acute worker
health and safety problems; and:
(h) Any trucked or hauled pollutants, except at points pre-designated by the
Discharger.
v.
The Discharger shall implement, as more completely set forth in
40 CFR 403.5, the legal authorities, programs, and controls necessary to
ensure that indirect discharges do not introduce pollutants into the sewerage
system that, either alone or in conjunction with a discharge or discharges
from other sources:
(a) Flow through the system to the receiving water in quantities or
concentrations that cause a violation of this Order, or:
(b) Inhibit or disrupt treatment processes, treatment system operations, or
sludge processes, use, or disposal and either cause a violation of this
Order or prevent sludge use or disposal in accordance with this Order.
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d. Collection System. On 2 May 2006, the State Water Board adopted State
Water Resources Control Board Order 2006-0003-DWQ, Statewide General
Waste Discharge Requirements (WDRs) for Sanitary Sewer Systems. The
Discharger shall be separately subject to the requirements of Order
2006-0003-DWQ and any future revisions thereto. Order 2006-0003-DWQ
requires that all public agencies that currently own or operate sanitary sewer
systems apply for coverage under the general WDRs. The Discharger has
applied for and has been approved for coverage, effective 16 October 2006,
under Order 2006-0003-DWQ for operation of its wastewater collection system.
6. Other Special Provisions
a. Phase 2 Improvements. The Discharger has requested an expansion of
allowable flows to be discharged to Old River. The permitted average dry
weather discharge flow may increase to 12 mgd upon compliance with the
following conditions:
i.
Facility Improvements. The Discharger shall have completed construction of
its Phase 2 improvements, which include construction of a second outfall
pipeline and diffuser and paving of additional sludge drying beds. The
Discharger shall provide certification of completion by the design engineer.
ii. Thermal Plan Compliance. The Discharger shall provide information
demonstrating the increased discharge will comply with Receiving Water
Limitations V.A.16.
iii. Request for Increase. The Discharger shall submit a request for an increase in
the permitted discharge flow rate, which demonstrates compliance with items i.
through ii., above. The increase in the permitted discharge flow rate shall not
be effective until the Executive Officer verifies compliance with Special
Provisions VI.C.6.a and approves the request.
b. Phase 3 Improvements. The Discharger has requested an expansion of
allowable flows to be discharged to Old River. The permitted average dry
weather discharge flow may increase to 13.6 mgd upon compliance with the
following conditions:
i.
Facility Improvements. The Discharger shall have completed construction of
its Phase 3 improvements, which include construction of one aeration basin and
secondary clarifier, installation of a new filter pump for tertiary treatment, and
paving of sludge drying beds. The Discharger shall provide certification of
completion by the design engineer.
ii. Thermal Plan Compliance. The Discharger shall provide information
demonstrating the increased discharge will comply with Receiving Water
Limitations V.A.16.
iii. Request for Increase. The Discharger shall submit a request for an increase in
the permitted discharge flow rate, which demonstrates compliance with items i.
through ii., above. The increase in the permitted discharge flow rate shall not
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ORDER R5-2012-0115
NPDES NO. CA0079154
be effective until the Executive Officer verifies compliance with Special
Provisions VI.C.6.a and approves the request.
c. Phase 4 Improvements. The Discharger has requested an expansion of
allowable flows to be discharged to Old River. The permitted average dry
weather discharge flow may increase to 16 mgd upon compliance with the
following conditions:
i.
Facility Improvements. The Discharger shall have completed construction of
its Phase 4 improvements, which include construction of a new primary clarifier,
replacement of two effluent pumps with larger capacity pumps, construction of a
sludge digester, and paving the remaining sludge drying beds. The Discharger
shall provide certification of completion by the design engineer.
ii. Thermal Plan Compliance. The Discharger shall provide information
demonstrating the increased discharge will comply with Receiving Water
Limitations V.A.16.
iii. Request for Increase. The Discharger shall submit a request for an increase in
the permitted discharge flow rate, which demonstrates compliance with items i.
through ii., above. The increase in the permitted discharge flow rate shall not
be effective until the Executive Officer verifies compliance with Special
Provisions VI.C.6.a and approves the request.
d. Title 22, or Equivalent, Disinfection Requirements. Wastewater shall be
oxidized, coagulated, filtered, and adequately disinfected pursuant to the
Department of Public Health (DPH) reclamation criteria, CCR, Title 22, division 4,
chapter 3, (Title 22), or equivalent.
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ORDER R5-2012-0115
NPDES NO. CA0079154
7. Compliance Schedules
a. Compliance Schedule for Final Effluent Limitations for Methylmercury. This
Order requires compliance with the final effluent limitations for methylmercury by
31 December 2030. The Discharger shall comply with the following time
schedule to ensure compliance with the final effluent limitations:
Task
Date Due
Phase 1
i.
Submit CVCWA Coordinated Methylmercury Control Study Work Plan
ii.
Update and Implement Pollution Prevention Plan (PPP) for Mercury
(per Section VI.C.3.a)
1
20 April 2013
1 June 2013
iii. Submit Mercury Exposure Reduction Work Plan (per Section VI.C.3.b)
20 October 2013
iv. Implement CVCWA Coordinated Methylmercury Control Study Work
Plan
Immediately following
Executive Officer Approval
v.
6 months following
Executive Officer Approval
Implement Mercury Exposure Reduction Work Plan
(per Section VI.C.3.b)
vi. Annual Progress Reports
2
20 October 2014
20 October 2015
20 October 2016
20 October 2017
vii. Submit CVCWA Coordinated Methylmercury Control Study Progress
Report
20 October 2015
viii. Submit Final CVCWA Coordinated Methylmercury Control Study
20 October 2018
4
Phase 2
ix. Implement methylmercury control programs
x.
1
2
3
4
TBD
3
3
31 December 2030
Full Compliance
The PPP for Mercury shall be updated and implemented in accordance with Section VI.C.3.a. The
Discharger shall continue to implement its existing PPP for mercury during the period in which it updates
the PPP.
The progress reports shall detail what steps have been implemented towards achieving compliance with
waste discharge requirements, including studies, construction progress, evaluation of measures
implemented, sources of funding, and recommendations for additional measures as necessary to
achieve full compliance by the final compliance date.
To be determined. Following Phase 1 the Central Valley Water Board will conduct a Phase 1 Delta
Mercury Control Program Review that considers: modification of methylmercury goals, objectives,
allocations, final compliance date, etc. Consequently, the start of Phase 2 and the final compliance date
is uncertain at the time this Order was adopted.
The Executive Officer may, after public notice, extend the due date for the Final CVCWA Coordinated
Methylmercury Control Study up to two years if the Discharger demonstrates it is making significant
progress towards developing, implementing and/or completing the Study and reasonable attempts have
been made to secure funding for the Study, but the Discharger has experienced severe budget
shortfalls.
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CITY OF TRACY
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ORDER R5-2012-0115
NPDES NO. CA0079154
VII. COMPLIANCE DETERMINATION
A. BOD5 and TSS Effluent Limitations (Section IV.A.1.a and b). Compliance with the
final effluent limitations for BOD5 and TSS required in Limitations and Discharge
Requirements Section IV.A.1.a shall be ascertained by 24-hour composite samples.
Compliance with effluent limitations required in Limitations and Discharge Requirements
Section IV.A.1.b for percent removal shall be calculated using the arithmetic mean of
BOD5 and TSS in effluent samples collected over a monthly period as a percentage of
the arithmetic mean of the values for influent samples collected at approximately the
same times during the same period.
A. Total Calendar Annual Mass Loading Effluent Limitations (Total Dissolved Solids,
Section IV.A.1.f, and Total Mercury, Section IV.A.2.a). The procedures for calculating
calendar annual mass loading are as follows:
1. The total pollutant mass load for each individual calendar month shall be determined
using an average of all concentration data collected that month and the
corresponding total monthly flow. All effluent monitoring data collected under the
monitoring and reporting program, pretreatment program, and any special studies
shall be used for these calculations. The total calendar annual mass loading shall be
the sum of the individual calendar months.
2. In calculating compliance, the Discharger shall count all non-detect measures at onehalf of the method detection level. If compliance with the effluent limitation is not
attained due to the non-detect contribution, the Discharger shall improve and
implement available analytical capabilities and compliance shall be evaluated with
consideration of the method detection limits.
B. Average Dry Weather Flow Effluent Limitations (Section IV.A.1.j). The average dry
weather discharge flow represents the daily average flow when groundwater is at or
near normal and runoff is not occurring. Compliance with the average dry weather flow
effluent limitations will be determined annually based on the average daily flow over
three consecutive dry weather months (e.g., July, August, and September).
C. Total Coliform Organisms Effluent Limitations (Section IV.A.1.h). For each day that
an effluent sample is collected and analyzed for total coliform organisms, the 7-day
median shall be determined by calculating the median concentration of total coliform
bacteria in the effluent utilizing the bacteriological results of the last 7 days. For
example, if a sample is collected on a Wednesday, the result from that sampling event
and all results from the previous 6 days (i.e., Tuesday, Monday, Sunday, Saturday,
Friday, and Thursday) are used to calculate the 7-day median. If the 7-day median of
total coliform organisms exceeds a most probable number (MPN) of 2.2 per 100
milliliters, the Discharger will be considered out of compliance.
D. Total Residual Chlorine Effluent Limitations (Section IV.A.1.e). Continuous
monitoring analyzers for chlorine residual or for dechlorination agent residual in the
effluent are appropriate methods for compliance determination. A positive residual
dechlorination agent in the effluent indicates that chlorine is not present in the discharge,
Limitations and Discharge Requirements
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CITY OF TRACY
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NPDES NO. CA0079154
which demonstrates compliance with the effluent limitations. This type of monitoring can
also be used to prove that some chlorine residual exceedances are false positives.
Continuous monitoring data showing either a positive dechlorination agent residual or a
chlorine residual at or below the prescribed limit are sufficient to show compliance with
the total residual chlorine effluent limitations, as long as the instruments are maintained
and calibrated in accordance with the manufacturer’s recommendations.
Any excursion above the 1-hour average or 4-day average total residual chlorine effluent
limitations is a violation. If the Discharger conducts continuous monitoring and the
Discharger can demonstrate, through data collected from a back-up monitoring system,
that a chlorine spike recorded by the continuous monitor was not actually due to
chlorine, then any excursion resulting from the recorded spike will not be considered an
exceedance, but rather reported as a false positive. Records supporting validation of
false positives shall be maintained in accordance with Section IV Standard Provisions
(Attachment D).
E. Mass Effluent Limitations. The mass effluent limitations contained in the Final Effluent
Limitations IV.A.1.a are based on the permitted average dry weather flow and calculated
as follows:.
Mass (lbs/day) = Flow (MGD) x Concentration (mg/L) x 8.34 (conversion factor)
If the effluent flow exceeds the permitted average dry weather flow during wet-weather,
the effluent mass limitations contained in Final Effluent Limitations IV.A.1.a shall not
apply. If the effluent flow is below the permitted average dry weather flow during wetweather, the effluent mass limitations do apply.
F. Priority Pollutant Effluent Limitations. Compliance with effluent limitations for priority
pollutants shall be determined using sample reporting protocols defined in Attachment A
and Attachment E of this Order. For purposes of reporting and administrative
enforcement by the Central Valley Water Board and the State Water Board, the
Discharger shall be deemed out of compliance with effluent limitations if the
concentration of the priority pollutant in the effluent sample is greater than the effluent
limitation and greater than or equal to the reporting level (RL), per Section 2.4.5 of the
SIP.
G. Chronic Whole Effluent Toxicity Effluent Limitation (Section IV.A.1.g). Compliance
with the accelerated monitoring and TRE provisions of Provision VI.C.2.a shall
constitute compliance with the effluent limitation.
H. Temperature Receiving Water Limitations (Section V.A.16.b). Effective immediately
and until discharge at Discharge Point No. 002 commences, compliance with the
temperature receiving water limitation will be determined based on the difference in the
temperature measured at RSW-002 as compared to the downstream at RSW-003.
Effective when discharge at Discharge Point No. 002 commences, compliance with the
temperature receiving water limitation will be determined based on the difference in the
temperature measured at RSW-002 as compared to the downstream at RSW-004.
Limitations and Discharge Requirements
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ORDER R5-2012-0115
NPDES NO. CA0079154
I. Turbidity Receiving Water Limitations (Section V.A.18.a-e). Effective immediately
and until discharge at Discharge Point No. 002 commences, compliance with the
turbidity receiving water limitations will be determined based on the change in turbidity
measured at RSW-002 as compared to the downstream at RSW-003. Effective when
discharge at Discharge Point No. 002 commences, compliance with the turbidity
receiving water limitations will be determined based on the change in turbidity measured
at RSW-002 as compared to the downstream at RSW-004.
J. Temperature Effluent Limitations (Section IV.A.1.d). Compliance with the final
effluent limitations for temperature shall be ascertained using the daily average effluent
temperature at monitoring location EFF-001 and the temperature of the receiving water
measured on the same day by grab sample at RSW-001.
L. Chlorpyrifos and Diazinon Effluent Limitations (Section IV.A.1.k). Compliance shall
be determined by calculating the sum (S), as provided in this Order, with analytical
results that are reported as “non-detectable” concentrations to be considered to be zero.
Limitations and Discharge Requirements
34
CITY OF TRACY
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ORDER R5-2012-0115
NPDES NO. CA0079154
A.
ATTACHMENT A – DEFINITIONS
Acute Toxic Unit (TUa)
The reciprocal of the effluent concentration that causes 50 percent of the organisms to die in
an acute toxicity test (TUa = 100/LC50) (see LC50).
Arithmetic Mean ()
Also called the average, is the sum of measured values divided by the number of samples.
For ambient water concentrations, the arithmetic mean is calculated as follows:
Arithmetic mean =  = x / n
where: x is the sum of the measured ambient water
concentrations, and n is the number of
samples.
Average Monthly Effluent Limitation (AMEL)
The highest allowable average of daily discharges over a calendar month, calculated as the
sum of all daily discharges measured during a calendar month divided by the number of daily
discharges measured during that month.
Average Weekly Effluent Limitation (AWEL)
The highest allowable average of daily discharges over a calendar week (Sunday through
Saturday), calculated as the sum of all daily discharges measured during a calendar week
divided by the number of daily discharges measured during that week.
Best Practicable Treatment or Control (BPTC)
BPTC is a requirement of State Water Resources Control Board Resolution 68-16 –
“Statement of Policy with Respect to Maintaining High Quality of Waters in California” (referred
to as the “Antidegradation Policy”). BPTC is the treatment or control of a discharge necessary
to assure that, “(a) a pollution or nuisance will not occur and (b) the highest water quality
consistent with maximum benefit to the people of the State will be maintained.” Pollution is
defined in CWC Section 13050(I). In general, an exceedance of a water quality objective in
the Basin Plan constitutes “pollution”.
Bioaccumulative
Those substances taken up by an organism from its surrounding medium through gill
membranes, epithelial tissue, or from food and subsequently concentrated and retained in the
body of the organism.
Biosolids
Sludge that has been treated and tested and shown to be capable of being beneficially and
legally used pursuant to federal and state regulations as a soil amendment for agriculture,
silviculture, horticulture, and land reclamation activities.
Carcinogenic
Pollutants are substances that are known to cause cancer in living organisms.
Attachment A – Definitions
A-1
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Chronic Toxic Unit (TUc)
The reciprocal of the effluent concentration that causes no observable effect on the test
organisms in a chronic toxicity test (TUc = 100/NOEC) (see NOEC).
Coefficient of Variation (CV)
CV is a measure of the data variability and is calculated as the estimated standard deviation
divided by the arithmetic mean of the observed values.
Daily Discharge
Daily Discharge is defined as either: (1) the total mass of the constituent discharged over the
calendar day (12:00 am through 11:59 pm) or any 24-hour period that reasonably represents a
calendar day for purposes of sampling (as specified in the permit), for a constituent with
limitations expressed in units of mass or; (2) the unweighted arithmetic mean measurement of
the constituent over the day for a constituent with limitations expressed in other units of
measurement (e.g., concentration).
The daily discharge may be determined by the analytical results of a composite sample taken
over the course of 1 day (a calendar day or other 24-hour period defined as a day) or by the
arithmetic mean of analytical results from one or more grab samples taken over the course of
the day.
For composite sampling, if 1 day is defined as a 24-hour period other than a calendar day, the
analytical result for the 24-hour period will be considered as the result for the calendar day in
which the 24-hour period ends.
Detected, but Not Quantified (DNQ)
DNQ are those sample results less than the RL, but greater than or equal to the laboratory’s
MDL.
Dilution Credit
Dilution Credit is the amount of dilution granted to a discharge in the calculation of a water
quality-based effluent limitation, based on the allowance of a specified mixing zone. It is
calculated from the dilution ratio or determined through conducting a mixing zone study or
modeling of the discharge and receiving water.
Effect Concentration (EC)
A point estimate of the toxicant concentration that would cause an observable adverse effect
(e.g. death, immobilization, or serious incapitation) in a given percent of the test organisms,
calculated from a continuous model (e.g. Probit Model). EC25 is a point estimate of the
toxicant concentration that would cause an observable adverse effect in 25 percent of the test
organisms.
Effluent Concentration Allowance (ECA)
ECA is a value derived from the water quality criterion/objective, dilution credit, and ambient
background concentration that is used, in conjunction with the coefficient of variation for the
effluent monitoring data, to calculate a long-term average (LTA) discharge concentration. The
ECA has the same meaning as waste load allocation (WLA) as used in USEPA guidance
Attachment A – Definitions
A-2
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
(Technical Support Document For Water Quality-based Toxics Control, March 1991, second
printing, EPA/505/2-90-001).
Enclosed Bays
Enclosed Bays means indentations along the coast that enclose an area of oceanic water
within distinct headlands or harbor works. Enclosed bays include all bays where the narrowest
distance between the headlands or outermost harbor works is less than 75 percent of the
greatest dimension of the enclosed portion of the bay. Enclosed bays include, but are not
limited to, Humboldt Bay, Bodega Harbor, Tomales Bay, Drake’s Estero, San Francisco Bay,
Morro Bay, Los Angeles-Long Beach Harbor, Upper and Lower Newport Bay, Mission Bay,
and San Diego Bay. Enclosed bays do not include inland surface waters or ocean waters.
Estimated Chemical Concentration
The estimated chemical concentration that results from the confirmed detection of the
substance by the analytical method below the ML value.
Estuaries
Estuaries means waters, including coastal lagoons, located at the mouths of streams that
serve as areas of mixing for fresh and ocean waters. Coastal lagoons and mouths of streams
that are temporarily separated from the ocean by sandbars shall be considered estuaries.
Estuarine waters shall be considered to extend from a bay or the open ocean to a point
upstream where there is no significant mixing of fresh water and seawater. Estuarine waters
included, but are not limited to, the Sacramento-San Joaquin Delta, as defined in Water Code
section 12220, Suisun Bay, Carquinez Strait downstream to the Carquinez Bridge, and
appropriate areas of the Smith, Mad, Eel, Noyo, Russian, Klamath, San Diego, and Otay
rivers. Estuaries do not include inland surface waters or ocean waters.
Inhibition Concentration (IC)
A point estimate of the toxicant concentration that would cause a given percent reduction in a
non-lethal biological measurement (e.g. reproduction or growth), calculated from a continuous
model (e.g. Interpolation Method). IC25 is a point estimate of the toxicant concentration that
would cause a 25 percent reduction in a non-lethal biological measurement.
Inland Surface Waters
All surface waters of the State that do not include the ocean, enclosed bays, or estuaries.
Instantaneous Maximum Effluent Limitation
The highest allowable value for any single grab sample or aliquot (i.e., each grab sample or
aliquot is independently compared to the instantaneous maximum limitation).
Instantaneous Minimum Effluent Limitation
The lowest allowable value for any single grab sample or aliquot (i.e., each grab sample or
aliquot is independently compared to the instantaneous minimum limitation).
LC50, Lethal Concentration, 50 percent
The toxic or effluent concentration that would cause death in 50 percent of the test organisms
over a specified period of time.
Attachment A – Definitions
A-3
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
NOEC, No Observed Effect Concentration
The highest tested concentration of an effluent or test sample whose effect is not different from
the control effect, according to the statistical test used (see LOEC). The NOEC is usually the
highest tested concentration of an effluent or toxic that causes no observable effects on the
test organisms (i.e. the highest concentration of toxicity at which the values for the observed
responses do not statistically differ from the controls).
Maximum Daily Effluent Limitation (MDEL)
The highest allowable daily discharge of a pollutant, over a calendar day (or 24-hour period).
For pollutants with limitations expressed in units of mass, the daily discharge is calculated as
the total mass of the pollutant discharged over the day. For pollutants with limitations
expressed in other units of measurement, the daily discharge is calculated as the arithmetic
mean measurement of the pollutant over the day.
Median
The middle measurement in a set of data. The median of a set of data is found by first
arranging the measurements in order of magnitude (either increasing or decreasing order). If
the number of measurements (n) is odd, then the median = X(n+1)/2. If n is even, then the
median = (Xn/2 + X(n/2)+1)/2 (i.e., the midpoint between the n/2 and n/2+1).
Method Detection Limit (MDL)
MDL is the minimum concentration of a substance that can be measured and reported with 99
percent confidence that the analyte concentration is greater than zero, as defined in
40 CFR Part 136, Attachment B, revised as of 3 July 1999.
Minimum Level (ML)
ML is the concentration at which the entire analytical system must give a recognizable signal
and acceptable calibration point. The ML is the concentration in a sample that is equivalent to
the concentration of the lowest calibration standard analyzed by a specific analytical
procedure, assuming that all the method specified sample weights, volumes, and processing
steps have been followed.
Mixing Zone
Mixing Zone is a limited volume of receiving water that is allocated for mixing with a
wastewater discharge where water quality criteria can be exceeded without causing adverse
effects to the overall water body.
Not Detected (ND)
Sample results which are less than the laboratory’s MDL.
Ocean Waters
The territorial marine waters of the State as defined by California law to the extent these
waters are outside of enclosed bays, estuaries, and coastal lagoons. Discharges to ocean
waters are regulated in accordance with the State Water Board’s California Ocean Plan.
Persistent Pollutants
Persistent pollutants are substances for which degradation or decomposition in the
environment is nonexistent or very slow.
Attachment A – Definitions
A-4
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Pollutant Minimization Program (PMP)
PMP means waste minimization and pollution prevention actions that include, but are not
limited to, product substitution, waste stream recycling, alternative waste management
methods, and education of the public and businesses. The goal of the PMP shall be to reduce
all potential sources of a priority pollutant(s) through pollutant minimization (control) strategies,
including pollution prevention measures as appropriate, to maintain the effluent concentration
at or below the water quality-based effluent limitation. Pollution prevention measures may be
particularly appropriate for persistent bioaccumulative priority pollutants where there is
evidence that beneficial uses are being impacted. The Central Valley Water Board may
consider cost effectiveness when establishing the requirements of a PMP. The completion
and implementation of a Pollution Prevention Plan, if required pursuant to Water Code section
13263.3(d), shall be considered to fulfill the PMP requirements.
Pollution Prevention
Pollution Prevention means any action that causes a net reduction in the use or generation of
a hazardous substance or other pollutant that is discharged into water and includes, but is not
limited to, input change, operational improvement, production process change, and product
reformulation (as defined in Water Code section 13263.3). Pollution prevention does not
include actions that merely shift a pollutant in wastewater from one environmental medium to
another environmental medium, unless clear environmental benefits of such an approach are
identified to the satisfaction of the State or Regional Water Board.
Reporting Level (RL)
The RL is based on the proper application of method-based analytical procedures for sample
preparation and the absence of any matrix interferences. Other factors may be applied to the
RL depending on the specific sample preparation steps employed. For example, the treatment
typically applied in cases where there are matrix-effects is to dilute the sample or sample
aliquot by a factor of ten. In such cases, this additional factor must be applied in the
computation of the RL.
Residual Sludge
Sludge that will not be subject to further treatment at the Facility.
Satellite Collection System
The portion, if any, of a sanitary sewer system owned or operated by a different public agency
than the agency that owns and operates the wastewater treatment facility that a sanitary sewer
system is tributary to.
Source of Drinking Water
Any water designated as municipal or domestic supply (MUN) in a Regional Water Board
Basin Plan.
Standard Deviation ()
Standard Deviation is a measure of variability that is calculated as follows:
 = ([(x - )2]/(n – 1))0.5
where:
Attachment A – Definitions
A-5
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
x is the observed value;
 is the arithmetic mean of the observed values; and
n is the number of samples.
Sludge
The solid, semisolid, and liquid residues removed during primary, secondary, or advanced
wastewater treatment processes.
Solid Waste
Grit and screening material generated during preliminary treatment.
Toxicity Reduction Evaluation (TRE)
TRE is a study conducted in a step-wise process designed to identify the causative agents of
effluent or ambient toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity
control options, and then confirm the reduction in toxicity. The first steps of the TRE consist of
the collection of data relevant to the toxicity, including additional toxicity testing, and an
evaluation of facility operations and maintenance practices, and best management practices.
A Toxicity Identification Evaluation (TIE) may be required as part of the TRE, if appropriate. (A
TIE is a set of procedures to identify the specific chemical(s) responsible for toxicity. These
procedures are performed in three phases (characterization, identification, and confirmation)
using aquatic organism toxicity tests.)
Toxicity Test
The procedure using living organisms to determine whether a chemical or an effluent is toxic.
A toxicity test measures the degree of the effect of a specific chemical or effluent on exposed
test organisms.
Toxicity Unit
The measure of toxicity in an effluent as determined by the acute toxic units (TU a) or chronic
toxic units (TUc) measured. The larger the TU, the greater the toxicity.
Attachment A – Definitions
A-6
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
B.
ATTACHMENT B – MAP
N
Old River
Grant Line Canal
Old River
Discharge
Point 001
WWTP
City of
Tracy
Attachment B – Maps
B-1
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
C.
ATTACHMENT C – FLOW SCHEMATICS
MAIN WASTEWATER TREATMENT FACILITY
Attachment C – Flow Schematic
C-1
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
INDUSTRIAL WASTEWATER FACILITY
Industrial pretreatment units
leased from City of Tracy and
operated by Leprino Foods, Inc.
Leprino Wastewater
Influent Monitoring
Location (M-INFB)
Leprino Industrial
Influent
Lined Aerated
Lagoons
Unlined Aerated Oxidation Pond
Pond 2 (8 Acres)
Unlined Oxidation Pond
Pond 1 (8 Acres)
Screening
Unlined Oxidation Pond
Combined Pond 5 (15 Acres) and Pond 4 (14 Acres)
Unlined Oxidation Pond
Pond 3 (15 Acres)
To Main WWTP
Primary Clarifiers
Attachment C – Flow Schematic
C-2
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
D.
ATTACHMENT D – STANDARD PROVISIONS
I.
STANDARD PROVISIONS – PERMIT COMPLIANCE
A. Duty to Comply
1. The Discharger must comply with all of the conditions of this Order. Any
noncompliance constitutes a violation of the Clean Water Act (CWA) and the
California Water Code (Water Code) and is grounds for enforcement action, for
permit termination, revocation and reissuance, or modification; or denial of a permit
renewal application. (40 CFR 122.41(a).)
2. The Discharger shall comply with effluent standards or prohibitions established
under section 307(a) of the CWA for toxic pollutants and with standards for sewage
sludge use or disposal established under section 405(d) of the CWA within the
time provided in the regulations that establish these standards or prohibitions, even
if this Order has not yet been modified to incorporate the requirement.
(40 CFR 122.41(a)(1).)
B. Need to Halt or Reduce Activity Not a Defense
It shall not be a defense for a Discharger in an enforcement action that it would have
been necessary to halt or reduce the permitted activity in order to maintain compliance
with the conditions of this Order. (40 CFR 122.41(c))
C. Duty to Mitigate
The Discharger shall take all reasonable steps to minimize or prevent any discharge
or sludge use or disposal in violation of this Order that has a reasonable likelihood of
adversely affecting human health or the environment. (40 CFR 122.41(d))
D. Proper Operation and Maintenance
The Discharger shall at all times properly operate and maintain all facilities and
systems of treatment and control (and related appurtenances) which are installed or
used by the Discharger to achieve compliance with the conditions of this Order.
Proper operation and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures. This provision requires the operation of
backup or auxiliary facilities or similar systems that are installed by a Discharger only
when necessary to achieve compliance with the conditions of this Order.
(40 CFR 122.41(e).)
E. Property Rights
1. This Order does not convey any property rights of any sort or any exclusive
privileges. (40 CFR 122.41(g))
Attachment D – Standard Provisions
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
2. The issuance of this Order does not authorize any injury to persons or property or
invasion of other private rights, or any infringement of state or local law or
regulations. (40 CFR 122.5(c))
F. Inspection and Entry
The Discharger shall allow the Regional Water Board, State Water Board, United
States Environmental Protection Agency (USEPA), and/or their authorized
representatives (including an authorized contractor acting as their representative),
upon the presentation of credentials and other documents, as may be required by law,
to (40 CFR 122.41(i); Water Code section 13383):
3. Enter upon the Discharger's premises where a regulated facility or activity is
located or conducted, or where records are kept under the conditions of this Order
(40 CFR 122.41(i)(1));
4. Have access to and copy, at reasonable times, any records that must be kept
under the conditions of this Order (40 CFR 122.41(i)(2));
5. Inspect and photograph, at reasonable times, any facilities, equipment (including
monitoring and control equipment), practices, or operations regulated or required
under this Order (40 CFR 122.41(i)(3)); and
6. Sample or monitor, at reasonable times, for the purposes of assuring Order
compliance or as otherwise authorized by the CWA or the Water Code, any
substances or parameters at any location. (40 CFR 122.41(i)(4))
G. Bypass
7. Definitions
a. “Bypass” means the intentional diversion of waste streams from any portion of
a treatment facility. (40 CFR 122.41(m)(1)(i))
b. “Severe property damage” means substantial physical damage to property,
damage to the treatment facilities, which causes them to become inoperable, or
substantial and permanent loss of natural resources that can reasonably be
expected to occur in the absence of a bypass. Severe property damage does
not mean economic loss caused by delays in production.
(40 CFR 122.41(m)(1)(ii))
8. Bypass not exceeding limitations. The Discharger may allow any bypass to occur
which does not cause exceedances of effluent limitations, but only if it is for
essential maintenance to assure efficient operation. These bypasses are not
subject to the provisions listed in Standard Provisions – Permit Compliance I.G.3,
I.G.4, and I.G.5 below. (40 CFR 122.41(m)(2))
Attachment D – Standard Provisions
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
9. Prohibition of bypass. Bypass is prohibited, and the Regional Water Board may
take enforcement action against a Discharger for bypass, unless
(40 CFR 122.41(m)(4)(i)):
a. Bypass was unavoidable to prevent loss of life, personal injury, or severe
property damage (40 CFR 122.41(m)(4)(i)(A));
b. There were no feasible alternatives to the bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes, or maintenance during
normal periods of equipment downtime. This condition is not satisfied if
adequate back-up equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass that occurred during
normal periods of equipment downtime or preventive maintenance
(40 CFR 122.41(m)(4)(i)(B)); and
c. The Discharger submitted notice to the Regional Water Board as required
under Standard Provisions – Permit Compliance I.G.5 below.
(40 CFR 122.41(m)(4)(i)(C))
10. The Regional Water Board may approve an anticipated bypass, after considering
its adverse effects, if the Regional Water Board determines that it will meet the
three conditions listed in Standard Provisions – Permit Compliance I.G.3 above.
(40 CFR 122.41(m)(4)(ii))
11. Notice
d. Anticipated bypass. If the Discharger knows in advance of the need for a
bypass, it shall submit a notice, if possible at least 10 days before the date of
the bypass. (40 CFR 122.41(m)(3)(i))
e. Unanticipated bypass. The Discharger shall submit notice of an unanticipated
bypass as required in Standard Provisions - Reporting V.E below (24-hour
notice). (40 CFR 122.41(m)(3)(ii))
H. Upset
Upset means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the Discharger. An upset does not include
noncompliance to the extent caused by operational error, improperly designed
treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or
careless or improper operation. (40 CFR 122.41(n)(1))
12. Effect of an upset. An upset constitutes an affirmative defense to an action
brought for noncompliance with such technology based permit effluent limitations if
the requirements of Standard Provisions – Permit Compliance I.H.2 below are met.
No determination made during administrative review of claims that noncompliance
Attachment D – Standard Provisions
D-3
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
was caused by upset, and before an action for noncompliance, is final
administrative action subject to judicial review. (40 CFR 122.41(n)(2))
13. Conditions necessary for a demonstration of upset. A Discharger who wishes to
establish the affirmative defense of upset shall demonstrate, through properly
signed, contemporaneous operating logs or other relevant evidence that
(40 CFR 122.41(n)(3)):
f. An upset occurred and that the Discharger can identify the cause(s) of the
upset (40 CFR 122.41(n)(3)(i));
g. The permitted facility was, at the time, being properly operated
(40 CFR 122.41(n)(3)(ii));
h. The Discharger submitted notice of the upset as required in Standard
Provisions – Reporting V.E.2.b below (24-hour notice)
(40 CFR 122.41(n)(3)(iii)); and
i. The Discharger complied with any remedial measures required under Standard
Provisions – Permit Compliance I.C above. (40 CFR 122.41(n)(3)(iv))
14. Burden of proof. In any enforcement proceeding, the Discharger seeking to
establish the occurrence of an upset has the burden of proof.
(40 CFR 122.41(n)(4))
II.
STANDARD PROVISIONS – PERMIT ACTION
A. General
This Order may be modified, revoked and reissued, or terminated for cause. The filing
of a request by the Discharger for modification, revocation and reissuance, or
termination, or a notification of planned changes or anticipated noncompliance does
not stay any Order condition. (40 CFR 122.41(f))
B. Duty to Reapply
If the Discharger wishes to continue an activity regulated by this Order after the
expiration date of this Order, the Discharger must apply for and obtain a new permit.
(40 CFR 122.41(b))
C. Transfers
This Order is not transferable to any person except after notice to the Regional Water
Board. The Regional Water Board may require modification or revocation and
reissuance of the Order to change the name of the Discharger and incorporate such
other requirements as may be necessary under the CWA and the Water Code.
(40 CFR 122.41(l)(3) and 122.61)
Attachment D – Standard Provisions
D-4
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
VIII. STANDARD PROVISIONS – MONITORING
A. Samples and measurements taken for the purpose of monitoring shall be
representative of the monitored activity. (40 CFR 122.41(j)(1))
B. Monitoring results must be conducted according to test procedures under
40 CFR Part 136 or, in the case of sludge use or disposal, approved under
40 CFR Part 136 unless otherwise specified in 40 CFR Part 503 unless other test
procedures have been specified in this Order. (40 CFR 122.41(j)(4) and
122.44(i)(1)(iv))
IX.
STANDARD PROVISIONS – RECORDS
A. Except for records of monitoring information required by this Order related to the
Discharger's sewage sludge use and disposal activities, which shall be retained for a
period of at least 5 years (or longer as required by 40 CFR Part 503), the Discharger
shall retain records of all monitoring information, including all calibration and
maintenance records and all original strip chart recordings for continuous monitoring
instrumentation, copies of all reports required by this Order, and records of all data
used to complete the application for this Order, for a period of at least three (3) years
from the date of the sample, measurement, report or application. This period may be
extended by request of the Regional Water Board Executive Officer at any time.
(40 CFR 122.41(j)(2))
B. Records of monitoring information shall include:
1. The date, exact place, and time of sampling or measurements
(40 CFR 122.41(j)(3)(i));
2. The individual(s) who performed the sampling or measurements
(40 CFR 122.41(j)(3)(ii));
3. The date(s) analyses were performed (40 CFR 122.41(j)(3)(iii));
4. The individual(s) who performed the analyses (40 CFR 122.41(j)(3)(iv));
5. The analytical techniques or methods used (40 CFR 122.41(j)(3)(v)); and
6. The results of such analyses. (40 CFR 122.41(j)(3)(vi))
C. Claims of confidentiality for the following information will be denied
(40 CFR 122.7(b)):
1. The name and address of any permit applicant or Discharger
(40 CFR 122.7(b)(1)); and
2. Permit applications and attachments, permits and effluent data.
(40 CFR 122.7(b)(2))
Attachment D – Standard Provisions
D-5
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
X.
ORDER R5-2012-0115
NPDES NO. CA0079154
STANDARD PROVISIONS – REPORTING
A. Duty to Provide Information
The Discharger shall furnish to the Regional Water Board, State Water Board, or
USEPA within a reasonable time, any information which the Regional Water Board,
State Water Board, or USEPA may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating this Order or to determine
compliance with this Order. Upon request, the Discharger shall also furnish to the
Regional Water Board, State Water Board, or USEPA copies of records required to be
kept by this Order. (40 CFR 122.41(h); Water Code, § 13267)
B. Signatory and Certification Requirements
1. All applications, reports, or information submitted to the Regional Water Board,
State Water Board, and/or USEPA shall be signed and certified in accordance with
Standard Provisions – Reporting V.B.2, V.B.3, V.B.4, and V.B.5 below.
(40 CFR 122.41(k))
2. All permit applications shall be signed by either a principal executive officer or
ranking elected official. For purposes of this provision, a principal executive officer
of a federal agency includes: (i) the chief executive officer of the agency, or (ii) a
senior executive officer having responsibility for the overall operations of a principal
geographic unit of the agency (e.g., Regional Administrators of USEPA).
(40 CFR 122.22(a)(3))
3. All reports required by this Order and other information requested by the Regional
Water Board, State Water Board, or USEPA shall be signed by a person described
in Standard Provisions – Reporting V.B.2 above, or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
a. The authorization is made in writing by a person described in Standard
Provisions – Reporting V.B.2 above (40 CFR 122.22(b)(1));
b. The authorization specifies either an individual or a position having
responsibility for the overall operation of the regulated facility or activity such as
the position of plant manager, operator of a well or a well field, superintendent,
position of equivalent responsibility, or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized
representative may thus be either a named individual or any individual
occupying a named position.) (40 CFR 122.22(b)(2)); and
c. The written authorization is submitted to the Regional Water Board and State
Water Board. (40 CFR 122.22(b)(3))
4. If an authorization under Standard Provisions – Reporting V.B.3 above is no longer
accurate because a different individual or position has responsibility for the overall
operation of the facility, a new authorization satisfying the requirements of
Attachment D – Standard Provisions
D-6
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Standard Provisions – Reporting V.B.3 above must be submitted to the Regional
Water Board and State Water Board prior to or together with any reports,
information, or applications, to be signed by an authorized representative.
(40 CFR 122.22(c))
5. Any person signing a document under Standard Provisions – Reporting V.B.2 or
V.B.3 above shall make the following certification:
“I certify under penalty of law that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system
or those persons directly responsible for gathering the information, the information
submitted is, to the best of my knowledge and belief, true, accurate, and complete.
I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.”
(40 CFR 122.22(d))
C. Monitoring Reports
1. Monitoring results shall be reported at the intervals specified in the Monitoring and
Reporting Program (Attachment E) in this Order. (40 CFR 122.22(l)(4))
2. Monitoring results must be reported on a Discharge Monitoring Report (DMR) form
or forms provided or specified by the Regional Water Board or State Water Board
for reporting results of monitoring of sludge use or disposal practices.
(40 CFR 122.41(l)(4)(i))
3. If the Discharger monitors any pollutant more frequently than required by this
Order using test procedures approved under 40 CFR Part 136 or, in the case of
sludge use or disposal, approved under 40 CFR Part 136 unless otherwise
specified in 40 CFR Part 503, or as specified in this Order, the results of this
monitoring shall be included in the calculation and reporting of the data submitted
in the DMR or sludge reporting form specified by the Regional Water Board.
(40 CFR 122.41(l)(4)(ii))
4. Calculations for all limitations, which require averaging of measurements, shall
utilize an arithmetic mean unless otherwise specified in this Order.
(40 CFR 122.41(l)(4)(iii))
D. Compliance Schedules
Reports of compliance or noncompliance with, or any progress reports on, interim and
final requirements contained in any compliance schedule of this Order, shall be
submitted no later than 14 days following each schedule date. (40 CFR 122.41(l)(5))
Attachment D – Standard Provisions
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
E. Twenty-Four Hour Reporting
1. The Discharger shall notify the Office of Emergency Services of any
noncompliance that may endanger health or the environment within two (2) hours
from the time the Discharger becomes aware of the circumstances. The
Discharger shall notify the Central Valley Water Board of the noncompliance by
telephone or fax within 24 hours from the time the Discharger becomes aware of
the circumstances. A written submission shall also be provided to the Central
Valley Water Board within five (5) days of the time the Discharger becomes aware
of the circumstances. The written submission shall contain a description of the
noncompliance and its cause; the period of noncompliance, including exact dates
and times, and if the noncompliance has not been corrected, the anticipated time it
is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance. (40 CFR 122.41(l)(6)(i))
2. The following shall be included as information that must be reported within
24 hours under this paragraph (40 CFR 122.41(l)(6)(ii)):
a. Any unanticipated bypass that exceeds any effluent limitation in this Order.
(40 CFR 122.41(l)(6)(ii)(A))
b. Any upset that exceeds any effluent limitation in this Order.
(40 CFR 122.41(l)(6)(ii)(B))
3. The Regional Water Board may waive the above-required written report under this
provision on a case-by-case basis if an oral report has been received within
24 hours. (40 CFR 122.41(l)(6)(iii))
F. Planned Changes
The Discharger shall give notice to the Regional Water Board as soon as possible of
any planned physical alterations or additions to the permitted facility. Notice is
required under this provision only when (40 CFR 122.41(l)(1)):
1. The alteration or addition to a permitted facility may meet one of the criteria for
determining whether a facility is a new source in 40 CFR 122.29(b)
(40 CFR 122.41(l)(1)(i)); or
2. The alteration or addition could significantly change the nature or increase the
quantity of pollutants discharged. This notification applies to pollutants that are not
subject to effluent limitations in this Order. (40 CFR 122.41(l)(1)(ii))
The alteration or addition could significantly change the nature or increase the
quantity of pollutants discharged. This notification applies to pollutants that are
subject neither to effluent limitations in this Order nor to notification requirements
under 40 CFR 122.42(a)(1) (see Additional Provisions—Notification
Levels VII.A.1). (40 CFR 122.41(l)(1)(ii))
Attachment D – Standard Provisions
D-8
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
G. Anticipated Noncompliance
The Discharger shall give advance notice to the Regional Water Board or State Water
Board of any planned changes in the permitted facility or activity that may result in
noncompliance with General Order requirements. (40 CFR 122.41(l)(2))
H. Other Noncompliance
The Discharger shall report all instances of noncompliance not reported under
Standard Provisions – Reporting V.C, V.D, and V.E above at the time monitoring
reports are submitted. The reports shall contain the information listed in Standard
Provision – Reporting V.E above. (40 CFR 122.41(l)(7))
I. Other Information
When the Discharger becomes aware that it failed to submit any relevant facts in a
permit application, or submitted incorrect information in a permit application or in any
report to the Regional Water Board, State Water Board, or USEPA, the Discharger
shall promptly submit such facts or information. (40 CFR 122.41(l)(8))
XI.
STANDARD PROVISIONS – ENFORCEMENT
A. The Regional Water Board is authorized to enforce the terms of this permit under
several provisions of the Water Code, including, but not limited to, sections 13385,
13386, and 13387.
XII. ADDITIONAL PROVISIONS – NOTIFICATION LEVELS
A. Publicly-Owned Treatment Works (POTWs)
All POTWs shall provide adequate notice to the Regional Water Board of the following
(40 CFR 122.42(b)):
1. Any new introduction of pollutants into the POTW from an indirect discharger that
would be subject to sections 301 or 306 of the CWA if it were directly discharging
those pollutants (40 CFR 122.42(b)(1)); and
2. Any substantial change in the volume or character of pollutants being introduced
into that POTW by a source introducing pollutants into the POTW at the time of
adoption of the Order. (40 CFR 122.42(b)(2))
3. Adequate notice shall include information on the quality and quantity of effluent
introduced into the POTW as well as any anticipated impact of the change on the
quantity or quality of effluent to be discharged from the POTW.
(40 CFR 122.42(b)(3))
Attachment D – Standard Provisions
D-9
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
E.
ATTACHMENT E – MONITORING AND REPORTING PROGRAM
Table of Contents
I.
II.
III.
General Monitoring Provisions ........................................................................................ E-2
Monitoring Locations ...................................................................................................... E-3
Influent Monitoring Requirements ................................................................................... E-6
A. Monitoring Locations INF-001 and INF-002 ............................................................. E-6
IV. Effluent Monitoring Requirements .................................................................................. E-7
A. Monitoring Location EFF-001 ................................................................................... E-7
V. Whole Effluent Toxicity Testing Requirements ............................................................... E-8
VI. Land Discharge Monitoring Requirements (Set forth in Order R5-2007-0038) ............. E-11
VII. Reclamation Monitoring Requirements (NOT APPLICABLE) ....................................... E-11
VIII. Receiving Water Monitoring Requirements – Surface Water and Groundwater ........... E-12
A. Monitoring Location RSW-001, RSW-002, RSW-003, and RSW-004 .................... E-12
IX. Other Monitoring Requirements.................................................................................... E-13
A. Municipal Water Supply ......................................................................................... E-13
B. Tertiary Filtration .................................................................................................... E-13
X. Reporting Requirements ............................................................................................... E-14
A. General Monitoring and Reporting Requirements .................................................. E-14
B. Self Monitoring Reports (SMRs) ............................................................................ E-14
C. Discharge Monitoring Reports (DMRs) .................................................................. E-18
D. Other Reports ........................................................................................................ E-19
List of Tables
Table E-1.
Table E-2a.
Table E-2b.
Table E-3.
Table E-4.
Table E-5.
Table E-6.
Table E-7.
Table E-8.
Table E-9.
Monitoring Station Locations ............................................................................. E-3
Influent Monitoring ............................................................................................. E-6
Influent Monitoring ............................................................................................. E-6
Effluent Monitoring ............................................................................................ E-7
Chronic Toxicity Testing Dilution Series .......................................................... E-10
Receiving Water Monitoring Requirements ..................................................... E-12
Municipal Water Supply Monitoring Requirements .......................................... E-13
Disinfection System Monitoring ....................................................................... E-13
Monitoring Periods and Reporting Schedule ................................................... E-14
Reporting Requirements for Special Provisions Reports ................................ E-19
Attachment E – Monitoring And Reporting Program
E-1
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
ATTACHMENT E – MONITORING AND REPORTING PROGRAM
Title 40 of the Code of Federal Regulations (CFR), section 122.48 (40 CFR 122.48) requires
that all NPDES permits specify monitoring and reporting requirements. California Water Code
(Water Code) sections 13267 and 13383 also authorize the Regional Water Quality Control
Board, Central Valley Region (Central Valley Water Board) to require technical and monitoring
reports. This Monitoring and Reporting Program establishes monitoring and reporting
requirements, which implement the federal and California regulations.
I.
GENERAL MONITORING PROVISIONS
A. Samples and measurements taken as required herein shall be representative of the
volume and nature of the monitored discharge. All samples shall be taken at the
monitoring locations specified below and, unless otherwise specified, before the
monitored flow joins or is diluted by any other waste stream, body of water, or
substance. Monitoring locations shall not be changed without notification to and the
approval of the Central Valley Water Board.
B. Effluent samples shall be taken downstream of the last addition of wastes to the
treatment or discharge works where a representative sample may be obtained prior to
mixing with the receiving waters. Samples shall be collected at such a point and in
such a manner to ensure a representative sample of the discharge.
C. Chemical, bacteriological, and bioassay analyses of any material required by this
Order shall be conducted by a laboratory certified for such analyses by the
Department of Public Health (DPH). Laboratories that perform sample analyses must
be identified in all monitoring reports submitted to the Central Valley Water Board. In
the event a certified laboratory is not available to the Discharger for any onsite field
measurements such as pH, DO, turbidity, temperature, and residual chlorine, such
analyses performed by a noncertified laboratory will be accepted provided that the
analysis is in accordance with 40 CFR 136 or an USEPA approved alternative test
procedure, and a Quality Assurance-Quality Control Program is instituted by the
laboratory. A manual containing the steps followed in this program for any onsite field
measurements such as pH, DO, turbidity, temperature, and residual chlorine must be
kept onsite in the treatment facility laboratory and shall be available for inspection by
Central Valley Water Board staff. The Discharger must demonstrate sufficient
capability (qualified and trained employees, properly calibrated and maintained field
instruments, etc.) to adequately perform these field measurements. The Quality
Assurance-Quality Control Program must conform to USEPA guidelines or to
procedures approved by the Central Valley Water Board.
D. Appropriate flow measurement devices and methods consistent with accepted
scientific practices shall be selected and used to ensure the accuracy and reliability of
measurements of the volume of monitored discharges. All monitoring instruments and
devices used by the Discharger to fulfill the prescribed monitoring program shall be
properly maintained and calibrated as necessary, at least yearly, to ensure their
Attachment E – Monitoring And Reporting Program
E-2
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
continued accuracy. All flow measurement devices shall be calibrated at least once
per year to ensure continued accuracy of the devices.
E. Monitoring results, including noncompliance, shall be reported at intervals and in a
manner specified in this Monitoring and Reporting Program.
F. Laboratories analyzing monitoring samples shall be certified by DPH, in accordance
with the provision of CWC section 13176, and must include quality assurance/quality
control data with their reports.
G. The Discharger shall conduct analysis on any sample provided by USEPA as part of
the Discharge Monitoring Quality Assurance (DMQA) program. The results of any
such analysis shall be submitted to USEPA's DMQA manager.
H. The Discharger shall file with the Central Valley Water Board technical reports on selfmonitoring performed according to the detailed specifications contained in this
Monitoring and Reporting Program.
I. The results of all monitoring required by this Order shall be reported to the Central
Valley Water Board, and shall be submitted in such a format as to allow direct
comparison with the limitations and requirements of this Order. Unless otherwise
specified, discharge flows shall be reported in terms of the monthly average and the
daily maximum discharge flows.
II.
MONITORING LOCATIONS
The Discharger shall establish the following monitoring locations to demonstrate
compliance with the effluent limitations, discharge specifications, and other requirements
in this Order:
Table E-1. Monitoring Station Locations
Discharge Point
Name
--
-001, 002
Monitoring Location Description
INF-001
Domestic Influent to Facility
Leprino Foods Company Influent as measured at influent
to Treatment Pond 1 (see Attachment C, Figure C-2).
Effluent discharged through Outfall 001 and Outfall 002*,
measured at final effluent pump station
Old River, approximately 1 mile upstream of Outfall 001,
downstream of confluence with Middle River (37.8218ºN,
121.3735ºW) see Figure E-1
Old River, approximately 500 feet upstream of Outfall
001 (37.8057ºN, 121.3992ºW)
see Figure E-1a
Old River, approximately 500 feet downstream of Outfall
001 (37.8053ºN, 121.4025ºW)
see Figure E-1a
INF-002
2
1
Monitoring Location Name
EFF-001
-RSW-001
-RSW-002
-RSW-003
Attachment E – Monitoring And Reporting Program
E-3
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
Discharge Point
Name
--
ORDER R5-2012-0115
NPDES NO. CA0079154
Monitoring Location Name
Monitoring Location Description
1
Old River, approximately 500 feet downstream of Outfall
002 (37.8060ºN, 121.4051ºW)
see Figure E-1a
SPL-001
Municipal Water Supply
-Latitude and longitude coordinates are approximate.
Future outfall proposed for Facility expansion.
The Discharger is not required to monitor at R-004 until Discharge Point 002 is operational.
3
RSW-004
1
2
3
Attachment E – Monitoring And Reporting Program
E-4
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Figure E-1
Receiving Water Monitoring Locations
N
R-001
E-1a
E-1a
R-003
R-002
R-004
Outfall 001
Outfall 002
Attachment E – Monitoring And Reporting Program
E-5
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
III.
ORDER R5-2012-0115
NPDES NO. CA0079154
INFLUENT MONITORING REQUIREMENTS
A. Monitoring Locations INF-001 and INF-002
1. The Discharger shall monitor domestic influent to the facility at INF-001 as follows.
Influent samples shall be collected at approximately the same time as effluent
samples and shall be representative of the influent.
Table E-2a.
Influent Monitoring
Parameter
Flow
pH
BOD 5-day @ 20°C
Total Suspended Solids
Total Dissolved Solids
Electrical Conductivity
o
@ 25 C
1
2
3
Required
Analytical Test
Method
Units
Sample Type
Minimum Sampling
Frequency
MGD
Standard Units
mg/L
mg/L
mg/L
Meter
Meter
2
24-hr Composite
2
24-hr Composite
3
Grab
Continuous
Continuous
1/Day
1/Day
1/Week
1
µmhos/cm
Grab
1/Week
1
3
1
1
1
1
Pollutants shall be analyzed using the analytical methods described in 40 CFR Part 136 or an EPA
approved Alternate Testing Procedure; where no methods are specified for a given pollutant that meet a
specific reporting limit or method performance standard, an alternate method shall be approved by the
Central Valley Water Board.
24-hour flow proportional composite.
Grab samples shall not be collected at the same time each day to get a complete representation of
variations in the influent.
2. The Discharger shall monitor Leprino Foods Company influent to the facility at
INF-002 as follows. Influent samples shall be collected at approximately the same
time as effluent samples and shall be representative of the influent.
Table E-2b.
Influent Monitoring
Parameter
Units
Sample Type
Minimum Sampling
Frequency
BOD 5-day @ 20°C
Total Suspended Solids
Total Dissolved Solids
MGD
Standard Units
mg/L
mg/L
mg/L
Meter
Meter
2
24-hr Composite
2
24-hr Composite
3
Grab
Continuous
1/Week
1/Day
1/Day
1/Week
Flow
pH
Required
Analytical Test
Method
1
1
1
1
1
Electrical Conductivity
3
1
µmhos/cm
Grab
1/Week
o
@ 25 C
1
Pollutants shall be analyzed using the analytical methods described in 40 CFR Part 136 or an EPA
approved Alternate Testing Procedure; where no methods are specified for a given pollutant that meet a
specific reporting limit or method performance standard, an alternate method shall be approved by the
Central Valley Water Board.
2
24-hour flow proportional composite.
3
Grab samples shall not be collected at the same time each day to get a complete representation of
variations in the influent.
Attachment E – Monitoring And Reporting Program
E-6
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
IV.
ORDER R5-2012-0115
NPDES NO. CA0079154
EFFLUENT MONITORING REQUIREMENTS
A. Monitoring Location EFF-001
1. The Discharger shall monitor treated effluent that is discharged to Old River at
Discharge Point 001 and/or Discharge Point 002 at Monitoring Location EFF-001
as follows. Effluent samples shall be collected downstream from the last
connection through which wastes can be admitted into the outfall. Effluent
samples should be representative of the volume and quality of the discharge. If
more than one analytical test method is listed for a given parameter, the
Discharger must select from the listed methods and corresponding Minimum Level:
Table E-3.
Effluent Monitoring
Parameter
Discharge Location
Flow
14
Biochemical Oxygen Demand
(BOD) (5-day @ 20 Deg. C)
Total Suspended Solids
Units
Sample Type
-mgd
mg/L
lbs/day
mg/L
lbs/day
Standard Units
µg/L
µg/L
µg/L
µg/L
mg/L
mg/L
µmhos/cm
mg/L
µg/L
µg/L
µg/L
-Meter
2
24-hr Composite
Calculate
2
24-hr Composite
Calculate
Meter
Grab
Grab
Grab
Grab
Grab
Meter
Grab
Grab
Grab
Grab
Grab
Minimum
Sampling
Frequency
1/Day
Continuous
1/Day
1/Day
1/Day
1/Day
3
Continuous
1/Month
1/Quarter
1/Month
1/Month
3, 10
1/Week
Continuous
1/Week
11
1/Month
1/Quarter
1/Month
1/Month
Required
Analytical
Test Method
-1
1
-1
-1
pH
15
1, 4, 5
Bis (2-ethylhexyl) phthalate
15
Copper
15
Chlorodibromomethane
15
Dichlorobromomethane
1
Ammonia Nitrogen, Total (as N)
1, 9
Chlorine, Total Residual
1
Electrical Conductivity @ 25°C
1
Hardness (as CaCO3)
15
1, 11
Lead, Total Recoverable
15
12
Mercury, Total Recoverable
12
Mercury, Methyl
1
Nitrate + Nitrite
mg/L
Grab
1/Week
(as N)
3
1
Temperature
°F
Meter
Continuous
13
1
Total Coliform Organisms
MPN/100 mL
Grab
1/Day
Whole Effluent Toxicity (see
----Section V. below)
Priority Pollutants and Other
See
See
µg/L
See Attachment I
7, 15
Constituents of Concern
Attachment I
Attachment I
1
Pollutants shall be analyzed using the analytical methods described in 40 CFR Part 136 or an EPA approved
Alternate Testing Procedure; where no methods are specified for a given pollutant that meet a specific
reporting limit or method performance standard, an alternate method can be approved by the Central Valley
Water Board.
2
24-hour flow proportional composite.
3
pH and temperature shall be recorded at the time of ammonia sample collection.
Attachment E – Monitoring And Reporting Program
E-7
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
Minimum
Required
Sampling
Analytical
Frequency
Test Method
In order to verify if bis (2-ethylhexyl) phthalate is truly present in the effluent discharge, the Discharger shall
take steps to assure that sample containers, sampling apparatus, and analytical equipment are not sources of
the detected contaminant.
For priority pollutant constituents with effluent limitations, reporting limits shall be below the effluent
limitations. If the lowest minimum level (ML) published in Appendix 4 of the Policy for Implementation of
Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries of California (State
Implementation Plan or SIP) is not below the effluent limitation, the reporting limit shall be the lowest ML. For
priority pollutant constituents without effluent limitations, the detection limits shall be equal to or less than the
lowest ML published in Appendix 4 of the SIP. Sampling and analysis of Bis (2-ethylhexyl) phthalate shall be
conducted using ultra-clean techniques that eliminate the possibility of sample contamination.
Volatile constituents shall be sampled in accordance with 40 CFR Part 136 or by methods approved by the
Central Valley Water Board or the State Water Board.
Concurrent with receiving surface water sampling.
Total chlorine residual must be monitored with a method sensitive to and accurate at the permitted level of
0.01 mg/L.
Concurrent with whole effluent toxicity monitoring.
Hardness samples shall be collected concurrently with metals samples.
Unfiltered methyl mercury and total mercury samples shall be taken using clean hands/dirty hands
procedures, as described in U.S. EPA method 1669: Sampling Ambient Water for Trace Metals at EPA Water
Quality Criteria Levels, for collection of equipment blanks (section 9.4.4.2), and shall be analyzed by U.S.
EPA method 1630/1631 (Revision E) with a method detection limit of 0.02 ng/l for methyl mercury and 0.2 ng/l
for total mercury.
Samples for Total coliform organisms may be collected at any point following disinfection.
The Discharger shall report daily the discharge location used (i.e., Discharge Point No 001 and/or 002).
The maximum required Reporting Level is specified in Attachment I, Table I-1, Priority Pollutants and Other
Constituents of Concern.
Parameter
4
5
6
7
8
10
11
12
13
14
15
V.
ORDER R5-2012-0115
NPDES NO. CA0079154
Units
Sample Type
WHOLE EFFLUENT TOXICITY TESTING REQUIREMENTS
A. Acute Toxicity Testing. The Discharger shall conduct acute toxicity testing to
determine whether the effluent is contributing acute toxicity to the receiving water.
The Discharger shall meet the following acute toxicity testing requirements:
1. Monitoring Frequency – The Discharger shall perform monthly acute toxicity
testing, concurrent with effluent ammonia sampling.
2. Sample Types – The Discharger may use flow-through, static non-renewal, or
static renewal testing. For static non-renewal and static renewal testing, the
samples shall be flow proportional 24-hour composites and shall be representative
of the volume and quality of the discharge. The effluent samples shall be taken at
the effluent monitoring location EFF-001.
3. Test Species – Test species shall be rainbow trout (Oncorhchus mykiss).
4. Methods – The acute toxicity testing samples shall be analyzed using EPA-821-R02-012, Fifth Edition. Temperature, total residual chlorine, and pH shall be
recorded at the time of sample collection. No pH adjustment may be made unless
approved by the Executive Officer.
Attachment E – Monitoring And Reporting Program
E-8
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
5. Test Failure – If an acute toxicity test does not meet all test acceptability criteria, as
specified in the test method, the Discharger must re-sample and re-test as soon as
possible, not to exceed 7 days following notification of test failure.
B. Chronic Toxicity Testing. The Discharger shall conduct three species chronic toxicity
testing to determine whether the effluent is contributing chronic toxicity to the receiving
water. The Discharger shall meet the following chronic toxicity testing requirements:
1. Monitoring Frequency – The Discharger shall perform quarterly three species
chronic toxicity testing.
2. Sample Types – Effluent samples shall be flow proportional 24-hour composites
and shall be representative of the volume and quality of the discharge. The
effluent samples shall be taken at the effluent monitoring location EFF-001. The
receiving water control shall be a grab sample obtained from the RSW-001
sampling location, as identified in this Monitoring and Reporting Program.
3. Sample Volumes – Adequate sample volumes shall be collected to provide
renewal water to complete the test in the event that the discharge is intermittent.
4. Test Species – Chronic toxicity testing measures sublethal (e.g., reduced growth,
reproduction) and/or lethal effects to test organisms exposed to an effluent
compared to that of the control organisms. The Discharger shall conduct chronic
toxicity tests with:

The cladoceran, water flea, Ceriodaphnia dubia (survival and reproduction
test);

The fathead minnow, Pimephales promelas (larval survival and growth test);
and

The green alga, Selenastrum capricornutum (growth test).
5. Methods – The presence of chronic toxicity shall be estimated as specified in
Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving
Waters to Freshwater Organisms, Fourth Edition, EPA/821-R-02-013,
October 2002.
6. Reference Toxicant – As required by the SIP, all chronic toxicity tests shall be
conducted with concurrent testing with a reference toxicant and shall be reported
with the chronic toxicity test results.
7. Dilutions – For regular and accelerated chronic toxicity monitoring, it is not
necessary to perform the test using a dilution series. The test may be performed
using 100% effluent and two controls. For TRE monitoring, the chronic toxicity
testing shall be performed using the dilution series identified in Table E-4, below,
unless an alternative dilution series is detailed in the submitted TRE Action Plan.
The receiving water control shall be used as the diluent, unless use of an
Attachment E – Monitoring And Reporting Program
E-9
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
alternative diluent is detailed in the submitted TRE Action Plan, or when the
receiving water is toxic.
Table E-4.
Chronic Toxicity Testing Dilution Series
Dilutions (%)
Controls
Sample
100
75
50
25
12.5
Receiving
Water
Laboratory
Water
% Effluent
100
75
50
25
12.5
0
0
% Receiving Water
0
25
50
75
87.5
100
0
% Laboratory Water
0
0
0
0
0
0
100
8. Test Failure – The Discharger must re-sample and re-test as soon as possible, but
no later than fourteen (14) days after receiving notification of a test failure. A test
failure is defined as follows:
a. The reference toxicant test or the effluent test does not meet all test
acceptability criteria as specified in the Short-term Methods for Estimating the
Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms,
Fourth Edition, EPA/821-R-02-013, October 2002 (Method Manual), and its
subsequent amendments or revisions; or
b. The percent minimum significant difference (PMSD) measured for the test
exceeds the upper PMSD bound variability criterion in Table 6 on page 52 of
the Method Manual. (A retest is only required in this case if the test results do
not exceed the monitoring trigger specified in the Special Provision at section
VI. 2.a.iii. of the Order.)
C. WET Testing Notification Requirements. The Discharger shall notify the Central
Valley Water Board within 24-hours after the receipt of test results exceeding the
monitoring trigger during regular or accelerated monitoring, or an exceedance of the
acute toxicity effluent limitation.
D. WET Testing Reporting Requirements. All toxicity test reports shall include the
contracting laboratory’s complete report provided to the Discharger and shall be in
accordance with the appropriate “Report Preparation and Test Review” sections of the
method manuals. At a minimum, whole effluent toxicity monitoring shall be reported
as follows:
1. Chronic WET Reporting. Regular chronic toxicity monitoring results shall be
reported to the Central Valley Water Board within 30 days following completion of
the test, and shall contain, at minimum:
a. The results expressed in TUc, measured as 100/NOEC, and also measured as
100/LC50, 100/EC25, 100/IC25, and 100/IC50, as appropriate.
b. The statistical methods used to calculate endpoints;
Attachment E – Monitoring And Reporting Program
E-10
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
c. The statistical output page, which includes the calculation of the percent
minimum significant difference (PMSD);
d. The dates of sample collection and initiation of each toxicity test; and
e. The results compared to the numeric toxicity monitoring trigger.
Additionally, the monthly discharger self-monitoring reports shall contain an
updated chronology of chronic toxicity test results expressed in TUc, and
organized by test species, type of test (survival, growth or reproduction), and
monitoring frequency, i.e., either quarterly, monthly, accelerated, or Toxicity
Reduction Evaluation (TRE).
2. Acute WET Reporting. Acute toxicity test results shall be submitted with the
monthly discharger self-monitoring reports and reported as percent survival.
3. TRE Reporting. Reports for TREs shall be submitted in accordance with the
schedule contained in the Discharger’s approved TRE Workplan, or as amended
by the Discharger’s TRE Action Plan.
4. Quality Assurance (QA). The Discharger must provide the following information
for QA purposes:
a. Results of the applicable reference toxicant data with the statistical output page
giving the species, NOEC, LOEC, type of toxicant, dilution water used,
concentrations used, PMSD, and dates tested.
b. The reference toxicant control charts for each endpoint, which include
summaries of reference toxicant tests performed by the contracting laboratory.
c. Any information on deviations or problems encountered and how they were
dealt with.
VI.
LAND DISCHARGE MONITORING REQUIREMENTS (SET FORTH IN ORDER
R5-2007-0038)
VII. RECLAMATION MONITORING REQUIREMENTS (NOT APPLICABLE)
Attachment E – Monitoring And Reporting Program
E-11
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
VIII. RECEIVING WATER MONITORING REQUIREMENTS – SURFACE WATER AND
GROUNDWATER
A. Monitoring Location RSW-001, RSW-002, RSW-003, and RSW-004
1. The Discharger shall monitor Old River at RSW-001, RSW-002, RSW-003, and
RSW-0045 as follows:
Table E-5.
Receiving Water Monitoring Requirements
Parameter
Dissolved Oxygen
1
pH
1
Temperature
1
Electrical Conductivity
1
@ 25C
1, 2, 3
Ammonia (as N)
1
Turbidity
1
Hardness as CaCO3
Priority Pollutants and
Other Constituents of
4, 6
Concern
1
2
3
4
5
6
Units
Sample Type
mg/L
Standard Units
F (C)
µmhos/cm
Grab
Grab
Grab
Minimum Sampling
Frequency
1/Week
1/Week
1/Week
Grab
1/Week
mg/L
NTU
mg/L
µg/L
Grab
Grab
Grab
Grab
1/Week
1/Week
1/Month
See Attachment I
Required Analytical
Test Method
Sampling required at RSW-002, RSW-003, and RSW-004, only.
Temperature and pH shall be determined at the time of sample collection.
The ammonia method detection limit must be less than or equal to 0.5 mg/L.
Sampling required at RSW-001, only.
Monitoring at R-004 is not required until the discharge begins at Outfall 002.
The maximum required Reporting Level is specified in Attachment I, Table I-1, Priority Pollutants and Other
Constituents of Concern.
In conducting the receiving water sampling, a log shall be kept of the receiving water
conditions throughout the reach bounded by Stations R-002 and R-004. River Flow
direction shall be reported at time of each sampling event. Attention shall also
be given to the presence or absence of:
a.
b.
c.
d.
Floating or suspended matter
Discoloration
Bottom deposits, if visible
Aquatic life
e. Visible films, sheens or coatings
f. Fungi, slimes, or objectionable growths
g. Potential nuisance conditions
Notes on receiving water conditions shall be summarized in the monitoring report.
Attachment E – Monitoring And Reporting Program
E-12
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
IX.
ORDER R5-2012-0115
NPDES NO. CA0079154
OTHER MONITORING REQUIREMENTS
A. Municipal Water Supply
1. Monitoring Location SPL-001
The Discharger shall monitor the municipal water supply at SPL-001 as follows. A
sampling station shall be established where a representative sample of the
municipal water supply can be obtained. Municipal water supply samples shall be
collected at approximately the same time as effluent samples.
Table E-6.
Municipal Water Supply Monitoring Requirements
Parameter
Minimum Sampling
Frequency
1/Quarter
1/Quarter
Required Analytical
Test Method
mg/L
µmhos/cm
Sample
Type
Grab
Grab
mg/L
Grab
1/Year
2
Units
1
Total Dissolved Solids
Electrical Conductivity @
1
25°C
3
Standard Minerals
2
2
1
If the water supply is from more than one source, the total dissolved solids and electrical conductivity shall
be reported as a weighted average and include copies of supporting calculations.
2
Pollutants shall be analyzed using the analytical methods described in 40 CFR Part 136.
Standard minerals shall include all major cations and anions and include verification that the analysis is
complete (i.e., cation/anion balance).
3
B. Tertiary Filtration
1. Tertiary Filtration System Monitoring
The Discharger shall monitor the Tertiary Filtration system at EFF-001 as follows:
Table E-7.
Disinfection System Monitoring
Minimum Sampling
Frequency
1
Flow
MGD
Meter
Continuous
2
1, 3
Turbidity
NTU
Meter
Continuous
1
For continuous analyzers, the Discharger shall report documented routine meter maintenance activities
including date, time of day, and duration, in which the analyzer(s) is not in operation.
2
The turbidity meter shall be stationed immediately after the filters.
3
Report daily average turbidity and maximum.
Parameter
Units
Attachment E – Monitoring And Reporting Program
Sample Type
E-13
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
X.
ORDER R5-2012-0115
NPDES NO. CA0079154
REPORTING REQUIREMENTS
A. General Monitoring and Reporting Requirements
1. The Discharger shall comply with all Standard Provisions (Attachment D) related to
monitoring, reporting, and recordkeeping.
2. Upon written request of the Central Valley Water Board, the Discharger shall
submit a summary monitoring report. The report shall contain both tabular and
graphical summaries of the monitoring data obtained during the previous year(s).
3. Compliance Time Schedules. For compliance time schedules included in the
Order, the Discharger shall submit to the Central Valley Water Board, on or before
each compliance due date, the specified document or a written report detailing
compliance or noncompliance with the specific date and task. If noncompliance is
reported, the Discharger shall state the reasons for noncompliance and include an
estimate of the date when the Discharger will be in compliance. The Discharger
shall notify the Central Valley Water Board by letter when it returns to compliance
with the compliance time schedule.
4. The Discharger shall report to the Central Valley Water Board any toxic chemical
release data it reports to the State Emergency Response Commission within 15
days of reporting the data to the Commission pursuant to section 313 of the
"Emergency Planning and Community Right to Know Act” of 1986.
B. Self Monitoring Reports (SMRs)
1. The Discharger shall submit eSMRs using the State Water Board’s CIWQS
Program Web site (http:www.waterboards.ca.gov/ciwqs/index.html). The
Discharger shall maintain sufficient staffing and resources to ensure it submits
eSMRs during the effective duration of this Order. This includes provision of
training and supervision of individuals (e.g., Discharger personnel or consultant) on
how to prepare and submit eSMRs.
2. Monitoring periods and reporting for all required monitoring shall be completed
according to the following schedule:
Table E-8.
Sampling
Frequency
Continuous
1/Hour
Monitoring Periods and Reporting Schedule
1/Week
Monitoring Period
Monitoring Period
Begins On…
Permit effective date Continuous
Permit effective date Hourly
(Midnight through 11:59 PM) or any 24-hour
Permit effective date period that reasonably represents a calendar
day for purposes of sampling.
Permit effective date Sunday through Saturday
1/Month
Permit effective date
1/Day
First day of calendar month through last day
of calendar month
Attachment E – Monitoring And Reporting Program
SMR Due Date
Submit with monthly SMR
Submit with monthly SMR
Submit with monthly SMR
Submit with monthly SMR
First day of second
calendar month following
month of sampling
E-14
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
Sampling
Frequency
1/Quarter
1/Year
Monitoring Period
Begins On…
ORDER R5-2012-0115
NPDES NO. CA0079154
Monitoring Period
1 January through 31 March
1 April through 30 June
Permit effective date
1 July through 30 September
1 October through 31 December
Permit effective date 1 January through 31 December
SMR Due Date
1 May
1 August
1 November
1 February
1 February
3. Reporting Protocols. The Discharger shall report with each sample result the
applicable Reporting Level (RL) and the current Method Detection Limit (MDL), as
determined by the procedure in 40 CFR Part 136.
The Discharger shall report the results of analytical determinations for the
presence of chemical constituents in a sample using the following reporting
protocols:
a. Sample results greater than or equal to the RL shall be reported as measured
by the laboratory (i.e., the measured chemical concentration in the sample).
b. Sample results less than the RL, but greater than or equal to the laboratory’s
MDL, shall be reported as “Detected, but Not Quantified,” or DNQ. The
estimated chemical concentration of the sample shall also be reported.
For the purposes of data collection, the laboratory shall write the estimated
chemical concentration next to DNQ as well as the words “Estimated
Concentration” (may be shortened to “Est. Conc.”). The laboratory may, if such
information is available, include numerical estimates of the data quality for the
reported result. Numerical estimates of data quality may be percent accuracy
(+ a percentage of the reported value), numerical ranges (low to high), or any
other means considered appropriate by the laboratory.
c. Sample results less than the laboratory’s MDL shall be reported as “Not
Detected,” or ND.
d. Dischargers are to instruct laboratories to establish calibration standards so
that the ML value (or its equivalent if there is differential treatment of samples
relative to calibration standards) is the lowest calibration standard. At no time
is the Discharger to use analytical data derived from extrapolation beyond the
lowest point of the calibration curve.
4. Compliance Determination. Compliance with effluent limitations for priority
pollutants shall be determined using sample reporting protocols defined above and
in Attachment A of this Order. For purposes of reporting and administrative
enforcement by the Central Valley Water Board and the State Water Board, the
Discharger shall be deemed out of compliance with effluent limitations if the
concentration of the priority pollutant in the monitoring sample is greater than the
effluent limitation and greater than or equal to the reporting level (RL).
Attachment E – Monitoring And Reporting Program
E-15
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
5. Multiple Sample Data. When determining compliance with an AMEL, AWEL, or
MDEL for priority pollutants and more than one sample result is available, the
Discharger shall compute the arithmetic mean unless the data set contains one or
more reported determinations of “Detected, but Not Quantified” (DNQ) or “Not
Detected” (ND). In those cases, the Discharger shall compute the median in place
of the arithmetic mean in accordance with the following procedure:
a. The data set shall be ranked from low to high, ranking the reported ND
determinations lowest, DNQ determinations next, followed by quantified values
(if any). The order of the individual ND or DNQ determinations is unimportant.
b. The median value of the data set shall be determined. If the data set has an
odd number of data points, then the median is the middle value. If the data set
has an even number of data points, then the median is the average of the two
values around the middle unless one or both of the points are ND or DNQ, in
which case the median value shall be the lower of the two data points where
DNQ is lower than a value and ND is lower than DNQ.
6. Reporting Requirements. In reporting the monitoring data, the Discharger shall
arrange the data in tabular form so that the date, the constituents, and the
concentrations are readily discernible.
a. The data shall be summarized to clearly illustrate whether the facility is
operating in compliance with interim and/or final effluent limitations or with other
waste discharge requirements (e.g., discharge specifications, receiving water
limitations, special provisions, etc.).
b. Reports must clearly show when discharging to EFF-001 or other permitted
discharge locations. Reports must show the date and time that the discharge
started and stopped at each location.
c. The highest daily maximum for the month and monthly and weekly averages
shall be determined and recorded as needed to demonstrate compliance.
7. Calculation Requirements. The following shall be calculated and reported in the
SMRs:
a. Mass Loading Limitations. For BOD5, TSS, and ammonia, the Discharger
shall calculate and report the mass loading (lbs/day) in the SMRs. The mass
loading shall be calculated as follows:
Mass Loading (lbs/day) = Flow (MGD) x Concentration (mg/L) x 8.34
When calculating daily mass loading, the daily average flow and constituent
concentration shall be used. For weekly average mass loading, the weekly
average flow and constituent concentration shall be used. For monthly average
mass loading, the monthly average flow and constituent concentration shall be
used.
Attachment E – Monitoring And Reporting Program
E-16
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
b. Removal Efficiency (BOD5 and TSS). The Discharger shall calculate and
report the percent removal of BOD5 and TSS in the SMRs. The percent
removal shall be calculated as specified in Section VII.A. of the Limitations and
Discharge Requirements.
c. Total Coliform Organisms Effluent Limitations. The Discharger shall
calculate and report the 7-day median of total coliform organisms for the
effluent. The 7-day median of total coliform organisms shall be calculated as
specified in Section VII.C. of the Limitations and Discharge Requirements.
d. Dissolved Oxygen Receiving Water Limitations. The Discharger shall
calculate and report monthly in the self-monitoring report: i) the dissolved
oxygen concentration, ii) the percent of saturation in the main water mass, and
iii) the 95th percentile dissolved oxygen concentration.
e. Turbidity Receiving Water Limitations. The Discharger shall calculate and
report the turbidity increase in the receiving water applicable to the natural
turbidity condition specified in Section V.A.17.a-e. of the Limitations and
Discharge Requirements. The Discharger shall calculate and report the
turbidity change in the receiving water based on the difference in turbidity at
RSW-002 and RSW-003. When Discharge Point No. 002 is initiated the
calculation shall be based on the difference in turbidity at RSW-002 and
RSW-004.
f. Temperature Receiving Water Limitations. The Discharger shall calculate
and report the temperature increase in the receiving water based on the
difference in temperature at RSW-002 and RSW-003. When Discharge Point
No. 002 is initiated the calculation shall be based on the difference in
temperature at RSW-002 and RSW-004.
g. Chlorpyrifos and Diazinon Effluent Limitations (Section IV.A.1.l). The
Discharger shall calculate and report the value of SAMEL and SMDEL for the
effluent, using the equation in Effluent Limitations IV.A.1.l and consistent with
the Compliance Determination language specified in Section VII.K.
h. Total Calendar Annual Mass Loading Effluent Limitations. For constituents
with effluent limitations specified as “total calendar annual mass loading” (i.e.,
methylmercury, total dissolved solids and total mercury) the Discharger shall
report the total calendar annual mass loading in the December SMR. The total
calendar annual mass loading shall be calculated as specified in Section V.B of
the Limitations and Discharge Requirements.
8. The Discharger shall submit SMRs in accordance with the following requirements:
a. When electronic submittal of data is required and CIWQS does not provide for
entry into a tabular format within the system, the Discharger shall electronically
submit the data in a tabular format as an attachment. The Discharger is not
Attachment E – Monitoring And Reporting Program
E-17
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
required to duplicate the submittal of data that is entered in a tabular format
within CIWQS.
b. The Discharger shall attach a cover letter to the SMR. The information
contained in the cover letter shall clearly identify violations of the WDRs;
discuss corrective actions taken or planned; and the proposed time schedule
for corrective actions. Identified violations must include a description of the
requirement that was violated and a description of the violation.
c. SMRs must be submitted to the Central Valley Water Board, signed and
certified as required by the Standard Provisions (Attachment D), to the address
listed below:
Regional Water Quality Control Board
Central Valley Region
NPDES Compliance and Enforcement Unit
11020 Sun Center Dr., Suite #200
Rancho Cordova, CA 95670-6114
C. Discharge Monitoring Reports (DMRs)
1. As described in section X.B.1 above, at any time during the term of this permit, the
State Water Board or Central Valley Water Board may notify the Discharger to
electronically submit SMRs that will satisfy federal requirements for submittal of
Discharge Monitoring Reports (DMRs). Until such notification is given, the
Discharger shall submit DMRs in accordance with the requirements described
below.
2. DMRs must be signed and certified as required by the standard provisions
(Attachment D). The Discharger shall submit the original DMR and one copy of the
DMR to the address listed below:
STANDARD MAIL
State Water Resources Control Board
Division of Water Quality
c/o DMR Processing Center
PO Box 100
Sacramento, CA 95812-1000
FEDEX/UPS/
OTHER PRIVATE CARRIERS
State Water Resources Control Board
Division of Water Quality
c/o DMR Processing Center
1001 I Street, 15th Floor
Sacramento, CA 95814
3. All discharge monitoring results must be reported on the official USEPA pre-printed
DMR forms (EPA Form 3320-1). Forms that are self-generated will not be
accepted unless they follow the exact same format of EPA Form 3320-1.
Attachment E – Monitoring And Reporting Program
E-18
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
D. Other Reports
1. Special Study Reports and Progress Reports. As specified in the compliance
time schedules required in the Special Provisions contained in section VI of the
Order, special study and progress reports shall be submitted in accordance with
the following reporting requirements. At minimum, the progress reports shall
include a discussion of the status of final compliance, whether the Discharger is on
schedule to meet the final compliance date, and the remaining tasks to meet the
final compliance date.
Table E-9. Reporting Requirements for Special Provisions Reports
Reporting
Special Provision
Requirements
Pollution Prevention Plan for Mercury
(Special Provisions VI.C.3.a.)
1 December, annually
Salinity Reduction Plan
(Special Provisions VI.C.3.c.)
1 March, annually
2. The Discharger shall report the results of any special studies, acute and chronic
toxicity testing, TRE/TIE, PMP, and Pollution Prevention Plan required by Special
Provisions VI.C. of this Order. The Discharger shall report the progress in
satisfaction of compliance schedule dates specified in the Special Provision at
section VI.C.7 of this Order. The Discharger shall submit reports with the first
monthly SMR scheduled to be submitted on or immediately following the report
due date.
3. Within 60 days of permit adoption, the Discharger shall submit a report outlining
reporting levels (RLs), method detection limits, and analytical methods for
approval. The Discharger shall comply with the monitoring and reporting
requirements for CTR constituents as outlined in section 2.3 and 2.4 of the SIP.
The maximum required reporting levels for priority pollutant constituents shall be
based on the minimum levels (MLs) contained in Appendix 4 of the SIP,
determined in accordance with Section 2.4.2 and 2.4.3 of the SIP. In accordance
with Section 2.4.2 of the SIP, when there is more than one ML value for a given
substance, the Central Valley Water Board shall include as RLs, in the permit, all
ML values, and their associated analytical methods, listed in Appendix 4 that are
below the calculated effluent limitation. The Discharger may select any one of
those cited analytical methods for compliance determination. If no ML value is
below the effluent limitation, then the Central Valley Water Board shall select as
the RL, the lowest ML value, and its associated analytical method, listed in
Appendix 4 for inclusion in the permit. Table I-1 (Attachment I) provides required
maximum reporting levels in accordance with the SIP.
4. The Discharger’s sanitary sewer system collects wastewater using sewers, pipes,
pumps, and/or other conveyance systems and directs the raw sewage to the
wastewater treatment plant. A “sanitary sewer overflow” is defined as a discharge
to ground or surface water from the sanitary sewer system at any point upstream
Attachment E – Monitoring And Reporting Program
E-19
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
of the wastewater treatment plant. All violations must be reported as required in
Standard Provisions. Facilities (such as wet wells, regulated impoundments,
tanks, highlines, etc.) may be part of a sanitary sewer system and discharges to
these facilities are not considered sanitary sewer overflows, provided that the
waste is fully contained within these temporary storage facilities.
5. Effluent and Receiving Water Characterization Study. An effluent and
receiving water monitoring study is required to ensure adequate information is
available for the next permit renewal. During the third year of this permit term, the
Discharger shall conduct bi-monthly monitoring of the effluent at EFF-001 and of
the receiving water at RSW-001 for all priority pollutants and other constituents of
concern as described in Attachment I. To complete the SIP requirements for
Dioxin and Furan monitoring, during the term of this Order Dioxin and Furan
sampling shall be performed for three consecutive years during dry weather, as
described in Attachment J. The report shall be completed in conformance with the
following schedule.
Task
Compliance Date
i.
Submit Work Plan and Time
Schedule
1 January 2014
ii.
Conduct bi-monthly monitoring
for all constituents listed in
Table I-1 (Attachment I)
During third or fourth year of permit term
iii
Conduct three consecutive years
of dioxin and furans dry weather
monitoring (Attachment J)
During the term of this Order
iv. Submit Final Report
6 months following completion of final monitoring event
6. Annual Operations Report. By 30 January of each year, the Discharger shall
submit a written report to the Executive Officer containing the following:
a. The names, certificate grades, and general responsibilities of all persons
employed at the Facility.
b. The names and telephone numbers of persons to contact regarding the plant
for emergency and routine situations.
c. A statement certifying when the flow meter(s) and other monitoring instruments
and devices were last calibrated, including identification of who performed the
calibration.
d. A statement certifying whether the current operation and maintenance manual,
and contingency plan, reflect the wastewater treatment plant as currently
constructed and operated, and the dates when these documents were last
revised and last reviewed for adequacy.
Attachment E – Monitoring And Reporting Program
E-20
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
e. The Discharger may also be requested to submit an annual report to the
Central Valley Water Board with both tabular and graphical summaries of the
monitoring data obtained during the previous year. Any such request shall be
made in writing. The report shall discuss the compliance record. If violations
have occurred, the report shall also discuss the corrective actions taken and
planned to bring the discharge into full compliance with the waste discharge
requirements.
7. Annual Pretreatment Reporting Requirements. The Discharger shall submit
annually a report to the Central Valley Water Board, with copies to USEPA Region
9 and the State Water Board, describing the Discharger's pretreatment activities
over the previous 12 months. In the event that the Discharger is not in compliance
with any conditions or requirements of this Order, including noncompliance with
pretreatment audit/compliance inspection requirements, then the Discharger shall
also include the reasons for noncompliance and state how and when the
Discharger shall comply with such conditions and requirements.
An annual report shall be submitted by 28 February and include at least the
following items:
a. A summary of analytical results from representative, flow proportioned, 24-hour
composite sampling of the POTW's influent and effluent for those pollutants
USEPA has identified under section 307(a) of the CWA which are known or
suspected to be discharged by industrial users.
Sludge shall be sampled during the same 24-hour period and analyzed for the
same pollutants as the influent and effluent sampling and analysis. The sludge
analyzed shall be a composite sample of a minimum of 12 discrete samples
taken at equal time intervals over the 24-hour period. Wastewater and sludge
sampling and analysis shall be performed at least annually. The discharger
shall also provide any influent, effluent or sludge monitoring data for nonpriority
pollutants which may be causing or contributing to Interference, Pass-Through
or adversely impacting sludge quality. Sampling and analysis shall be
performed in accordance with the techniques prescribed in 40 CFR Part 136
and amendments thereto.
b. A discussion of Upset, Interference, or Pass-Through incidents, if any, at the
treatment plant, which the Discharger knows or suspects were caused by
industrial users of the POTW. The discussion shall include the reasons why
the incidents occurred, the corrective actions taken and, if known, the name
and address of, the industrial user(s) responsible. The discussion shall also
include a review of the applicable pollutant limitations to determine whether any
additional limitations, or changes to existing requirements, may be necessary to
prevent Pass-Through, Interference, or noncompliance with sludge disposal
requirements.
Attachment E – Monitoring And Reporting Program
E-21
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
c. The cumulative number of industrial users that the Discharger has notified
regarding Baseline Monitoring Reports and the cumulative number of industrial
user responses.
d. An updated list of the Discharger's industrial users including their names and
addresses, or a list of deletions and additions keyed to a previously submitted
list. The Discharger shall provide a brief explanation for each deletion. The list
shall identify the industrial users subject to federal categorical standards by
specifying which set(s) of standards are applicable. The list shall indicate which
categorical industries, or specific pollutants from each industry, are subject to
local limitations that are more stringent than the federal categorical standards.
The Discharger shall also list the noncategorical industrial users that are
subject only to local discharge limitations. The Discharger shall characterize the
compliance status through the year of record of each industrial user by
employing the following descriptions:
i.
complied with baseline monitoring report requirements (where applicable);
ii.
consistently achieved compliance;
iii.
inconsistently achieved compliance;
iv.
significantly violated applicable pretreatment requirements as defined by
40 CFR 403.8(f)(2)(vii);
v.
complied with schedule to achieve compliance (include the date final
compliance is required);
vi.
did not achieve compliance and not on a compliance schedule; and
vii. compliance status unknown.
A report describing the compliance status of each industrial user characterized
by the descriptions in items iii through vii above shall be submitted for each
calendar quarter within 21 days of the end of the quarter. The report shall
identify the specific compliance status of each such industrial user and shall
also identify the compliance status of the POTW with regards to
audit/pretreatment compliance inspection requirements. If none of the
aforementioned conditions exist, at a minimum, a letter indicating that all
industries are in compliance and no violations or changes to the pretreatment
program have occurred during the quarter must be submitted. The information
required in the fourth quarter report shall be included as part of the annual
report. This quarterly reporting requirement shall commence upon issuance of
this Order.
e. A summary of the inspection and sampling activities conducted by the
Discharger during the past year to gather information and data regarding the
industrial users. The summary shall include:
Attachment E – Monitoring And Reporting Program
E-22
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
i.
The names and addresses of the industrial users subjected to surveillance
and an explanation of whether they were inspected, sampled, or both and
the frequency of these activities at each user; and
ii.
The conclusions or results from the inspection or sampling of each
industrial user.
iii.
A summary of the compliance and enforcement activities during the past
year. The summary shall include the names and addresses of the
industrial users affected by the following actions:
iv.
Warning letters or notices of violation regarding the industrial users'
apparent noncompliance with federal categorical standards or local
discharge limitations. For each industrial user, identify whether the
apparent violation concerned the federal categorical standards or local
discharge limitations.
v.
Administrative orders regarding the industrial users noncompliance with
federal categorical standards or local discharge limitations. For each
industrial user, identify whether the violation concerned the federal
categorical standards or local discharge limitations.
vi.
Civil actions regarding the industrial users' noncompliance with federal
categorical standards or local discharge limitations. For each industrial
user, identify whether the violation concerned the federal categorical
standards or local discharge limitations.
vii. Criminal actions regarding the industrial users noncompliance with federal
categorical standards or local discharge limitations. For each industrial
user, identify whether the violation concerned the federal categorical
standards or local discharge limitations.
viii. Assessment of monetary penalties. For each industrial user identify the
amount of the penalties.
ix.
Restriction of flow to the POTW.
x.
Disconnection from discharge to the POTW.
xi.
A description of any significant changes in operating the pretreatment
program which differ from the information in the Discharger's approved
Pretreatment Program including, but not limited to, changes concerning:
the program's administrative structure, local industrial discharge
limitations, monitoring program or monitoring frequencies, legal authority
or enforcement policy, funding mechanisms, resource requirements, or
staffing levels.
xii. A summary of the annual pretreatment budget, including the cost of
pretreatment program functions and equipment purchases.
Attachment E – Monitoring And Reporting Program
E-23
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Duplicate signed copies of these Pretreatment Program reports shall be submitted
to the Central Valley Water Board and the:
State Water Resources Control Board
Division of Water Quality
1001 I Street or P.O. Box 100
Sacramento, CA 95812
and the
Regional Administrator
U.S. Environmental Protection Agency WTR-5
75 Hawthorne Street
San Francisco, CA 94105
Attachment E – Monitoring And Reporting Program
E-24
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
F.
ATTACHMENT F – FACT SHEET
Table of Contents
I.
II.
Permit Information .......................................................................................................... F-3
Facility Description ......................................................................................................... F-4
A. Description of Wastewater and Biosolids Treatment or Controls ............................. F-4
B. Discharge Points and Receiving Waters .................................................................. F-5
C. Summary of Existing Requirements and Self-Monitoring Report (SMR) Data ......... F-6
D. Compliance Summary.............................................................................................. F-7
E. Planned Changes .................................................................................................... F-7
III. Applicable Plans, Policies, and Regulations ................................................................... F-8
A. Legal Authorities ...................................................................................................... F-8
B. California Environmental Quality Act (CEQA) .......................................................... F-8
C. State and Federal Regulations, Policies, and Plans ................................................ F-8
D. Impaired Water Bodies on CWA 303(d) List .......................................................... F-13
E. Other Plans, Policies and Regulations ................................................................... F-14
IV. Rationale For Effluent Limitations and Discharge Specifications .................................. F-14
A. Discharge Prohibitions ........................................................................................... F-16
B. Technology-Based Effluent Limitations .................................................................. F-16
1. Scope and Authority........................................................................................... F-16
2. Applicable Technology-Based Effluent Limitations ............................................ F-17
C. Water Quality-Based Effluent Limitations (WQBELs)............................................. F-18
1. Scope and Authority........................................................................................... F-18
2. Applicable Beneficial Uses and Water Quality Criteria and Objectives .............. F-19
3. Determining the Need for WQBELS................................................................... F-45
4. WQBEL Calculations ......................................................................................... F-77
5. Whole Effluent Toxicity (WET) ........................................................................... F-79
D. Final Effluent Limitations ........................................................................................ F-82
E. Interim Effluent Limitations ..................................................................................... F-89
F. Land Discharge Specifications (see Order R5-2007-0038).................................... F-91
G. Reclamation Specifications (Not Applicable) ......................................................... F-91
V. Rationale for Receiving Water Limitations .................................................................... F-91
A. Surface Water ........................................................................................................ F-92
B. Groundwater. (Set forth in Order R5-2007-0038) .................................................. F-92
VI. Rationale for Monitoring and Reporting Requirements ................................................. F-92
A. Influent Monitoring ................................................................................................. F-92
B. Effluent Monitoring ................................................................................................. F-93
C. Whole Effluent Toxicity Testing Requirements ...................................................... F-94
D. Receiving Water Monitoring ................................................................................... F-95
E. Other Monitoring Requirements ............................................................................. F-95
VII. Rationale for Provisions ................................................................................................ F-95
A. Standard Provisions ............................................................................................... F-95
B. Special Provisions.................................................................................................. F-96
1. Reopener Provisions.......................................................................................... F-96
2. Special Studies and Additional Monitoring Requirements.................................. F-97
Attachment F – Fact Sheet
F-1
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
3. Best Management Practices and Pollution Prevention .................................... F-101
4. Construction, Operation, and Maintenance Specifications............................... F-106
5. Special Provisions for Municipal Facilities (POTWs Only) ............................... F-106
6. Other Special Provisions .................................................................................. F-107
7. Compliance Schedules .................................................................................... F-107
VIII. Public Participation ..................................................................................................... F-110
A. Notification of Interested Parties .......................................................................... F-110
B. Written Comments ............................................................................................... F-110
C. Public Hearing ..................................................................................................... F-110
D. Waste Discharge Requirements Petitions............................................................ F-111
E. Information and Copying ...................................................................................... F-111
F. Register of Interested Persons ............................................................................ F-111
G. Additional Information .......................................................................................... F-111
List of Tables
Table F-1.
Table F-2.
Table F-3a.
Table F-3b.
Table F-4.
Table F-5.
Table F-6.
Table F-7.
Table F-7a.
Table F-8.
Table F-8a.
Table F-9.
Table F-10.
Table F-11.
Table F-12.
Table F-13.
Table F-14.
Table F-15.
Table F-16.
Facility Information ............................................................................................ F-3
Historic Effluent Limitations and Monitoring Data .............................................. F-6
303 (d) List for Old River ................................................................................. F-13
303 (d) List for the Sacramento-San Joaquin Delta Waterways ...................... F-13
Summary of Technology-based Effluent Limitations ....................................... F-18
Basin Plan Beneficial Uses ............................................................................. F-20
Maximum Rolling 30-Day Average Effluent Volume Fractions (% Effluent) .... F-30
Zinc ECA Evaluation ....................................................................................... F-38
Copper ECA Evaluation .................................................................................. F-39
Cadmium ECA Evaluation ............................................................................... F-41
Lead ECA Evaluation ...................................................................................... F-42
Summary of ECA Evaluations for CTR Hardness-dependent Metals............. F-43
Lead Receiving Water CTR Criteria Comparison ............................................ F-47
Salinity Water Quality Criteria/Objectives ........................................................ F-73
Summary of Water Quality-Based Effluent Limitations .................................... F-78
Whole Effluent Chronic Toxicity Testing Results ............................................. F-81
Determination of Assimilative Capacity for CDBM and DCBM ........................ F-85
Summary of Final Effluent Limitations ............................................................. F-88
Interim Effluent Limitation Calculation Summary ............................................. F-91
Attachment F – Fact Sheet
F-2
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
ATTACHMENT F – FACT SHEET
As described in the Findings in section II of this Order, this Fact Sheet includes the legal
requirements and technical rationale that serve as the basis for the requirements of this Order.
This Order has been prepared under a standardized format to accommodate a broad range of
discharge requirements for Dischargers in California. Only those sections or subsections of
this Order that are specifically identified as “not applicable” have been determined not to apply
to this Discharger. Sections or subsections of this Order not specifically identified as “not
applicable” are fully applicable to this Discharger.
I.
PERMIT INFORMATION
The following table summarizes administrative information related to the Facility.
Table F-1.
Facility Information
WDID
Discharger
Name of Facility
Facility Address
5B390108001
City of Tracy
Tracy Wastewater Treatment Plant
3900 Holly Drive
Tracy, CA 95304
San Joaquin County
Facility Contact, Title and
Mr. Steve Bayley, Deputy Director of Public Works (209) 831-4434
Phone
Authorized Person to Sign
Mr. Steven Bayley, Deputy Director of Public Works
and Submit Reports
Mailing Address
SAME
Billing Address
SAME
Type of Facility
POTW
Major or Minor Facility
Major
Threat to Water Quality
Category 1
Complexity
Category A
Pretreatment Program
Y
Reclamation Requirements
Not Applicable
(1)
Facility Permitted Flow
10.8 mgd
(1)
Facility Design Flow
10.8 mgd
Watershed
Sacramento-San Joaquin Delta
Receiving Water
Old River
Receiving Water Type
Sacramento-San Joaquin Delta
1
Upon compliance with Special Provisions VI.C.7.d., the permitted flow may increase to 16 mgd.
Attachment F – Fact Sheet
F-3
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
A. The City of Tracy (hereinafter Discharger) is the owner and operator of the Tracy
Wastewater Treatment Plant (hereinafter Facility), a Publicly-Owned Domestic
Wastewater Treatment Works.
For the purposes of this Order, references to the “discharger” or “permittee” in
applicable federal and state laws, regulations, plans, or policy are held to be
equivalent to references to the Discharger herein.
B. The Facility discharges wastewater to Old River, a water of the United States, and
was previously regulated by Order R5-2007-0036-01, which was adopted on
4 May 2007, and amended by Order R5-2011-0012 on 3 February 2011and expired
on 1 May 2012. The terms and conditions of Order R5-2007-0036-01 were
automatically continued and remained in effect until new Waste Discharge
Requirements (WDRs) and National Pollutant Discharge Elimination System (NPDES)
permit are adopted pursuant to this Order.
C. The Discharger filed a report of waste discharge and submitted an application for
renewal of its WDRs and NPDES permit on 3 November 2011. Supplemental
information was requested on 17 November 2011 and received on 24 January 2012
and 5 March 2012. A site visit was conducted on 16 July 2012, to observe operations
and collect additional data to develop permit limitations and conditions.
D. This Order regulates the discharge of treated municipal wastewater from the Facility to
Old River. As discussed above, as part of its treatment train the Discharger utilizes
unlined industrial ponds, unlined sludge drying beds, and unlined sludge storage
basins, which discharge wastes to groundwater. Waste Discharge Requirements
Order R5-2007-0038 has been developed to regulate the incidental land discharges
from these treatment facilities, in order to protect groundwater.
II.
FACILITY DESCRIPTION
The Discharger provides sewerage service for the City of Tracy and serves a population
of approximately 83,000. The design daily average flow capacity of the Facility is
currently 10.8 million gallons per day (mgd).
A. Description of Wastewater and Biosolids Treatment or Controls
1. The Facility treats primarily domestic wastewater collected via the City of Tracy’s
wastewater collection system. The wastewater treatment plant also accepts
industrial food processing wastewater from Leprino through a segregated industrial
wastewater pipeline. The industrial food processing wastewater is pretreated in
separate treatment facilities, which are located at the Facility, and introduced into the
main treatment plant for final treatment and disposal, as discussed in more detail in
Section II.A.3., below.
2. The Discharger provides wastewater treatment and disposal services for residences,
businesses, and industries within the Tracy area. The Facility was originally
constructed in 1930 and has experienced four major expansions. The most recent
Attachment F – Fact Sheet
F-4
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
expansion was completed in August 2008, which increased the treatment capacity
from 9 mgd to 10.8 mgd and included nitrification, denitrification and tertiary filtration.
Additional improvements will be completed during the term of this Order and will
include construction of a second outfall near the existing outfall and paving of
additional sludge drying beds.
3. The Facility is composed of a main treatment facility and an industrial facility. The
main treatment facility consists of raw influent bar screening, primary sedimentation,
flow equalization, biological nutrient removal, secondary sedimentation, tertiary
filtration, chlorination, dechlorination and post-aeration. Biosolids are thickened by
dissolved air flotation, anaerobically digested, and dewatered in impermeable drying
beds. The dried biosolids are hauled off-site for land application or disposed in a
landfill.
The Discharger’s industrial facility consists of four unlined industrial ponds
(approximately 52 acres). In addition, Leprino, a local cheese manufacturer, leases
two lined aerated lagoons and one 8-acre unlined oxidation pond from the
Discharger for preliminary treatment of its industrial food processing wastewater and
discharges to the Facility under an industrial pretreatment permit issued by the
Discharger. Leprino transports its industrial wastewater to the Facility via a
segregated industrial waste line. Leprino employees operate and maintain the
industrial wastewater pipeline and leased pretreatment units. Leprino’s industrial
pretreatment program permit allows for a discharge of up to 850,000 gallons per day
of industrial food-processing wastewater. Compliance with Leprino’s industrial
pretreatment permit is measured prior to discharge to Pond 1 (see Attachment C,
Figure C-2). Leprino’s industrial wastewater and process water from the main
treatment plant are stored in the unlined industrial ponds and introduced into the
primary sedimentation basins of the main treatment facility for treatment and
disposal.
4. This Order only regulates the surface water discharge to Old River. Separate Waste
Discharge Requirements (WDR) Order R5-2007-0038 regulates discharges to land
at the Facility.
B. Discharge Points and Receiving Waters
1. The Facility is located in Section 21, T2S, R5E, MDB&M, as shown in
Attachment B (Figure B), a part of this Order.
2. Treated municipal wastewater is discharged at Discharge Point No. 001, located
3.5-miles north of the Facility, through a 72-foot diffuser that includes ten 8-inch
diameter risers spaced 8 feet on center. Discharge point 001 is located at Old
River near the junction of Paradise Cut, Tom Paine Slough, Salmon Slough, and
Sugar Cut Slough at a point Latitude 37o, 48’, 17” N and longitude 121o, 24’, 03”
W. In order to increase discharge capacity, the Discharger is planning to construct
a second outfall, Discharge Point 002, approximately 800 feet west of Discharge
Point 001. Discharge Point 002 will be located at a point Latitude 37º, 48’, 19” N
Attachment F – Fact Sheet
F-5
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
and longitude 121º, 24’, 13” W and will utilize a 77-foot diffuser that includes twelve
8-inch diameter risers spaced 7 feet on center. Both outfalls will be utilized to
discharge treated effluent.
3. Old River, in the vicinity of the discharge, is tidally influenced. River flow moves
upstream during the incoming or flood tide, while downstream flows occur during
the outgoing or ebb tide. Multiple dosing of the receiving water with effluent may
occur as the tide moves the water column upstream and downstream past the
outfall. Upstream San Joaquin River releases, tidal influences, the South Delta
Temporary Barriers Program, and State Water Project and Central Valley Project
pumping at Clifton Court Forebay affect the amount of flow in Old River. A more
detailed discussion of Old River hydrodynamics and dilution is provided in
Attachment F, Section IV.C.c.2.c.ii.
C. Summary of Existing Requirements and Self-Monitoring Report (SMR) Data
Effluent limitations and Discharge Specifications contained in Order R5-2007-0036001 for discharges from Discharge Point No. 001 (Monitoring Location EFF-001) and
representative monitoring data from the term of Order R5-2007-0036-01 are as
follows:
Table F-2.
Historic Effluent Limitations and Monitoring Data
Effluent Limitation
Parameter
Units
Aluminum (Total
Recoverable)
µg/L
462
mg/L
Average
Monthly
Average
Weekly
200
(Annual
Average)
--
755
310
21 (Annual
(2)
Average)
310
1.28
--
3.6
(4)
--
113
15
1126
(4)
1351
2002
--
2.1
158
(4)
189
280
20
1501
(4)
1801
2669
--
BOD 5-day 20 C
lbs/
day
BOD % removal
Chlorodibromomethane
Copper (Total
Recoverable)
Dichlorobromomethane
%
1.3
98
(4)
117
174
10
751
(4)
900
1334
85
µg/L
3.6
--
µg/L
9.1
µg/L
6.8
Ammonia (as
(3)
N)
lbs/
day
mg/L
o
Attachment F – Fact Sheet
Maximum
Daily
Monitoring Data
(1)
(August 2008 To December 2011)
Highest
Highest
Highest
Average
Average
Daily
Monthly
Weekly
Discharge
Discharge
Discharge
--
90
4.6
(4)
351
(4)
6.4
438
(4)
8.6
(4)
564
>98
--
--
7.6
28
--
28
--
10.4
5.9
--
5.9
--
9.5
40
--
40
F-6
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Effluent Limitation
Parameter
Units
Dissolved
(5)
Oxygen
Electrical
Conductivity
Iron (Total
Recoverable)
Nitrate (as N)
Nitrite (as N)
pH
Temperature
Average
Monthly
Average
Weekly
Maximum
Daily
mg/L
--
--
> 5.0
(Daily
Average)
µmhos/
cm
700
1000
--
1350
µg/L
--
--
mg/L
mg/L
Std.
Units
o
F
mg/L
10
1
--
Monitoring Data
(1)
(August 2008 To December 2011)
Highest
Highest
Highest
Average
Average
Daily
Monthly
Weekly
Discharge
Discharge
Discharge
--
--
> 5.2 (Daily
Average)
1317
1468
--
1569
300
--
--
54
---
---
8.5
0.5
---
---
--
6.5-8.5
--
--
7.69
(6)
(7)
(2)
(8)
----10
15
20
2.5
3.4
4.7
Total Suspended
751
1126
1501
lbs/
(4)
(4)
(4)
(4)
(4)
(4)
Solids
173
238
326
900
1351
1801
day
1334
2002
2669
(1)
Facility was upgraded to tertiary during August 2008.
(2)
Highest daily average based on complete data from August 2008 through December 2011.
(3)
Instantaneous minimum and maximum.
(4)
Facility capacity 10.8 MGD.
(5)
The daily average effluent DO concentration shall not be less than 5.0 mg/L.
(6)
Interim goal of a maximum 500 µmhos/cm electrical conductivity increase over the weighted average
electrical conductivity of the City of Tracy’s water supply.
(7)
The maximum temperature of the discharge shall not exceed the natural receiving water temperature by
o
more than 20 F.
(8)
o
The maximum observed difference between the discharge and natural receiving water 21 F.
D. Compliance Summary
The Discharger reported the following effluent limitation violations and mandatory
minimum penalties were assessed, as summarized below, for the period of August
2008 thru December 2011:
Date
Constituent
5 August 2008
10 September 2008
Aluminum
Aluminum
Reported
Result
290 µ/L
310 µ/L
22 October 2008
Dichlorobromomethane
40 µ/L
Effluent
Limitation
266 µ/L
266 µ/L
37 µ/L
(Interim TSO Limit)
E. Planned Changes
The Discharger is in the process of upgrading the Facility to improve treatment and
expand capacity. The treatment system capacity will be expanded to 16 mgd through
a four-phase expansion. Phase 1 of the upgrade and expansion was completed in
August 2008, which included an increase in capacity from 9 mgd to 10.8 mgd,
Attachment F – Fact Sheet
F-7
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
nitrification/denitrification and tertiary filtration. The Report of Waste Discharge
describes the proposed changes as follows:
1. Phases 2 – 4 (16 mgd Design Capacity). Phases 2-4 improvements expand the
treatment and discharge capacity to 16 mgd. The proposed Phase 2
improvements include construction of a second outfall near the existing outfall, and
paving of additional sludge drying beds using impermeable hydraulic asphalt
cement pavement. The proposed Phase 3 improvements include construction of
one primary clarifier, solids processing facility, installation of a new filter pump for
tertiary treatment, and paving of sludge drying beds. The proposed Phase 4
improvements include construction of a new secondary clarifier, aeration basin,
and replacement of two effluent pumps with larger capacity pumps, construction of
a sludge digester, and paving the remaining sludge drying beds. The proposed
initiation of operation of the Phase 2, 3 and 4 improvements are 2014, 2018, and
2025, respectively.
III.
APPLICABLE PLANS, POLICIES, AND REGULATIONS
The requirements contained in this Order are based on the applicable plans, policies, and
regulations identified in the Findings in section II of this Order. The applicable plans,
policies, and regulations relevant to the discharge include the following:
A. Legal Authorities
This Order is issued pursuant to regulations in the Clean Water Act (CWA) and the
California Water Code (Water Code) as specified in the Finding contained at section
II.C of this Order.
B. California Environmental Quality Act (CEQA)
This Order meets the requirements of CEQA as specified in the Finding contained at
section II.E of this Order.
C. State and Federal Regulations, Policies, and Plans
1. Water Quality Control Plans. This Order implements the following water quality
control plans as specified in the Finding contained at section II.H of this Order.
a. Water Quality Control Plan, Fourth Edition (Revised February 2007), for
the Sacramento and San Joaquin River Basins (Basin Plan)
The Basin Plan designates beneficial uses, establishes water quality objectives,
and contains implementation programs and policies to achieve those objectives
for all waters addressed through the plan. In addition, State Water Board
Resolution No. 88-63 requires that, with certain exceptions, the Regional Water
Board assign the municipal and domestic supply use to water bodies that do
not have beneficial uses listed in the Basin Plan. The beneficial uses of the
Sacramento-San Joaquin Delta, including Old River downstream of the
Attachment F – Fact Sheet
F-8
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
discharge, as identified in Table II-1 of the Basin Plan, are municipal and
domestic supply, agricultural supply, agricultural stock watering, industrial
process water supply, industrial service supply, water contact recreation, other
non-contact water recreation, warm freshwater aquatic habitat, cold freshwater
aquatic habitat, warm fish migration habitat, cold fish migration habitat, warm
spawning habitat, wildlife habitat, and navigation.
The Basin Plan on page II-1.00 states: “Protection and enhancement of existing
and potential beneficial uses are primary goals of water quality planning…” and
with respect to disposal of wastewaters states that “...disposal of wastewaters
is [not] a prohibited use of waters of the State; it is merely a use which cannot
be satisfied to the detriment of beneficial uses.”
The federal CWA section 101(a)(2), states: “it is the national goal that wherever
attainable, an interim goal of water quality which provides for the protection and
propagation of fish, shellfish, and wildlife, and for recreation in and on the water
be achieved by July 1, 1983.” Federal Regulations, developed to implement
the requirements of the CWA, create a rebuttable presumption that all waters
be designated as fishable and swimmable. Federal Regulations, 40 CFR
sections 131.2 and 131.10, require that all waters of the State regulated to
protect the beneficial uses of public water supply, protection and propagation of
fish, shell fish and wildlife, recreation in and on the water, agricultural, industrial
and other purposes including navigation. Section 131.3(e), 40 CFR, defines
existing beneficial uses as those uses actually attained after November 28,
1975, whether or not they are included in the water quality standards. Federal
Regulation, 40 CFR section 131.10 requires that uses be obtained by
implementing effluent limitations, requires that all downstream uses be
protected and states that in no case shall a state adopt waste transport or
waste assimilation as a beneficial use for any waters of the United States.
b. Water Quality Control Plan for Control of Temperature in the Coastal and
Interstate Water and Enclosed Bays and Estuaries of California (Thermal
Plan)
The State Water Board adopted a Water Quality Control Plan for Control of
Temperature in the Coastal and Interstate Waters and Enclosed Bays and
Estuaries of California (Thermal Plan) on 18 May 1972, and amended this plan
on 18 September 1975. This plan contains temperature objectives for inland
surface waters. The Thermal Plan is applicable to this discharge. For
purposes of the Thermal Plan, the Discharger is considered to be an Existing
Discharger of Elevated Temperature Waste. The Thermal Plan in section 5.A.,
requires the following:
“5.
Estuaries
A. Existing discharges
Attachment F – Fact Sheet
F-9
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
(1) Elevated temperature waste discharges shall comply with the
following:
a. The maximum temperature shall not exceed the natural
receiving water temperature by more than 20°F.
b. Elevated temperature waste discharges either individually or
combined with other discharges shall not create a zone, defined
by water temperatures of more than 1°F above natural receiving
water temperature, which exceeds 25 percent of the crosssectional area of a main river channel at any point.
c. No discharge shall cause a surface water temperature rise
greater than 4°F above the natural temperature of the receiving
waters at any time or place.
d. Additional limitations shall be imposed when necessary to
assure protection of beneficial uses.
(2) Thermal waste discharges shall comply with the provisions of 5A
(1) above and, in addition, the maximum temperature of thermal
waste discharges shall not exceed 86°F.”
Based on the Dischargers Final EIR, modeling indicates that Objective 5.A.(1)b of
the Thermal Plan, may be exceeded 3 months of the year at the expanded
discharge flow rate of 16 mgd. As described in the Final EIR for the expansion of
the Facility, the Discharger has proposed mitigation measures to ensure that any
thermal impacts will be less than significant. The previous Order required the
Discharger conduct four years of intensive monitoring of thermal impacts in the
vicinity of the outfall and evaluate the need for mitigation measures. This
information will be used to evaluate if the discharge can meet the Thermal Plan
requirements or whether a Thermal Plan exception will be needed prior to initiating
discharge from Discharge Point No. 002. If a Thermal Plan exception is requested,
the Discharger will be required to conduct consultations with the United States Fish
and Wildlife Services, National Marine Fisheries Service, and California Department
of Fish and Game to ensure the Thermal Plan exception is adequately protective of
aquatic species, including rare, threatened, and endangered species protected
under the Endangered Species Act. Prior to initiating discharge at Discharge Point
No. 002, the Discharger is required to ensure compliance with the Thermal Plan
and/or be granted a Thermal Plan exception by the Central Valley Water Board.
c. Water Quality Control Plan for the San Francisco Bay/Sacramento-San
Joaquin Delta Estuary (Bay-Delta Plan)
The Water Quality Control Plan for the San Francisco Bay/Sacramento-San
Joaquin Delta Estuary (Bay-Delta Plan) was adopted in May 1995 by the State
Water Board superseding the 1991 Bay-Delta Plan. The Bay-Delta Plan was
last updated on 13 December 2006. The Bay-Delta Plan identifies the
beneficial uses of the estuary and includes objectives for flow, salinity, and
endangered species protection.
Attachment F – Fact Sheet
F-10
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
The State Water Board adopted Decision 1641 (D-1641) on 29 December
1999, and revised on 15 March 2000. D-1641 implements flow objectives for
the Bay-Delta Estuary, approves a petition to change points of diversion of the
Central Valley Project and the State Water Project in the Southern Delta, and
approves a petition to change places of use and purposes of use of the Central
Valley Project.
The Bay-Delta Plan includes water quality objectives for Electrical Conductivity
(EC) for the South Delta in the vicinity of the discharge2. On 1 June 2011, the
Superior Court for Sacramento County entered a judgment and peremptory writ
of mandate in the matter of City of Tracy v. State Water Resources Control
Board (Case No; 34-2009-8000-392-CU-WM-GDS), ruling that the South Delta
salinity objectives shall not apply to the City of Tracy and other municipal
dischargers pending reconsideration of the South Delta salinity objectives and
adoption of a proper program of implementation that includes municipal
dischargers. The State Water Board is currently considering new salinity and
flow objectives in the South Delta that will address the Court Order. Therefore,
at the time this Order was adopted the South Delta salinity objectives were not
applicable to the Discharger.
2. National Toxics Rule (NTR) and California Toxics Rule (CTR). This Order
implements the NTR and CTR as specified in the Finding contained at section II.I
of this Order.
3. State Implementation Policy (SIP). This Order implements the SIP as specified
in the Finding contained at section II.I of this Order.
4. Alaska Rule. This Order is consistent with the Alaska Rule as specified in the
Finding contained at section II.L of this Order.
5. Antidegradation Policy. As specified in the Finding contained at section II.N of
this Order and as discussed in detail in the Fact Sheet (Attachment F, Section
IV.D.4.), the discharge is consistent with the antidegradation provisions of 40 CFR
section 131.12 and State Water Resources Control Board (State Water Board)
Resolution 68-16.
6. Anti-Backsliding Requirements. This Order is consistent with anti-backsliding
policies as specified in the Finding contained at section II.M of this Order.
Compliance with the anti-backsliding requirements is discussed in the Fact Sheet
(Attachment F, Section IV.D.3).
2
The Bay-Delta Plan includes water quality objectives at three locations in the South Delta for EC. The water
quality objectives are a 14-day running average EC of 700 µmhos/cm from 1 April – 31 Aug and a 14-day
running average EC of 1000 µmhos/cm from 1 September - 31 March.
Attachment F – Fact Sheet
F-11
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
7. Emergency Planning and Community Right to Know Act
Section 13263.6(a) of the Water Code, requires that “the Regional Water Board
shall prescribe effluent limitations as part of the waste discharge requirements of a
POTW for all substances that the most recent toxic chemical release data reported
to the state emergency response commission pursuant to Section 313 of the
Emergency Planning and Community Right to Know Act of 1986 (42 U.S.C. Sec.
11023) (EPCRA) indicate as discharged into the POTW, for which the State Water
Board or the Regional Water Board has established numeric water quality
objectives, and has determined that the discharge is or may be discharged at a
level which will cause, have the reasonable potential to cause, or contribute to, an
excursion above any numeric water quality objective”.
The Central Valley Water Board has adopted numeric water quality objectives in
the Basin Plan for the following constituents: arsenic, chlorpyrifos, copper,
diazinon, iron, and manganese. As detailed elsewhere in this Permit, available
effluent quality data indicate that of these constituents, only copper has a
reasonable potential to cause or contribute to an excursion above any numeric
water quality objectives included within the Basin Plan or in any State Water Board
plan.
The most recent toxic chemical data report does not indicate any reportable off-site
releases or discharges to the collection system for this Facility. Therefore, a
reasonable potential analysis based on information from EPCRA cannot be
conducted. Based on information from EPCRA, there is no reasonable potential to
cause or contribute to an excursion above any numeric water quality objectives
included within the Basin Plan or in any State Water Board plan, so no effluent
limitations are included in this permit pursuant to Water Code section 13263.6(a).
However, as detailed elsewhere in this Order, available effluent data indicate that
there are constituents present in the effluent that have a reasonable potential to
cause or contribute to exceedances of water quality standards and require
inclusion of effluent limitations based on federal and state laws and regulations.
8. Storm Water Requirements
USEPA promulgated federal regulations for storm water on 16 November 1990 in
40 CFR Parts 122, 123, and 124. The NPDES Industrial Storm Water Program
regulates storm water discharges from wastewater treatment facilities.
Wastewater treatment plants are applicable industries under the storm water
program and are obligated to comply with the federal regulations.
9. Endangered Species Act. This Order is consistent with the Endangered Species
Act as specified in the Finding contained at section II.P of this Order.
Attachment F – Fact Sheet
F-12
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
D. Impaired Water Bodies on CWA 303(d) List
1. Under section 303(d) of the 1972 CWA, states, territories and authorized tribes are
required to develop lists of water quality limited segments. The waters on these
lists do not meet water quality standards, even after point sources of pollution have
installed the minimum required levels of pollution control technology. On
30 November 2006 USEPA gave final approval to California's 2006 section 303(d)
List of Water Quality Limited Segments. The Basin Plan references this list of
Water Quality Limited Segments (WQLSs), which are defined as “…those sections
of lakes, streams, rivers or other fresh water bodies where water quality does not
meet (or is not expected to meet) water quality standards even after the application
of appropriate limitations for point sources (40 CFR Part 130, et seq.).” The Basin
Plan also states, “Additional treatment beyond minimum federal standards will be
imposed on dischargers to [WQLSs]. Dischargers will be assigned or allocated a
maximum allowable load of critical pollutants so that water quality objectives can
be met in the segment.” The listing for Old River between the San Joaquin River
and the Delta-Mendota Canal also includes dissolved oxygen (DO) deficiencies.
2. Total Maximum Daily Loads (TMDLs). USEPA requires the Central Valley Water
Board to develop TMDLs for each 303(d) listed pollutant and water body
combination. The status of each TMDL and applicable effluent limitations are
discussed in Tables F-3a and F-3b, below, for each specific pollutant.
Table F-3a. 303 (d) List for Old River
Pollutant
Potential
Sources
Proposed TMDL
Completion
Chlorpyrifos
Agriculture
Approved
10 October 2007
Electrical Conductivity
Unknown
2021
Low Dissolved Oxygen
Agriculture
2019
Total Dissolved Solids
Agriculture
2021
Table F-3b. 303 (d) List for the Sacramento-San Joaquin Delta Waterways, southern
portion
Pollutant
Potential
Sources
Proposed TMDL
Completion
Chlorpyrifos
Agriculture
Approved
10 October 2007
DDT
(Dichlorodiphenyltrichloroethane)
Agriculture
Diazinon
Agriculture
Approved
10 October 2007
Electrical Conductivity
Agriculture
2019
Attachment F – Fact Sheet
(1)
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Pollutant
Potential
Sources
Proposed TMDL
Completion
Chlorpyrifos
Agriculture
Approved
10 October 2007
DDT
(Dichlorodiphenyltrichloroethane)
Agriculture
Diazinon
Agriculture
Approved
10 October 2007
Invasive Species
Unknown
2019
Organo-chlorine Group A
Pesticides
Agriculture
(1)
Mercury
Resource
Extraction
Approved
20 October 2011
Unknown Toxicity
Unknown
2019
(1)
TMDL completion date will be updated when the next 303(d) list is updated.
3. The 303(d) listings and TMDLs have been considered in the development of the
Order. A pollutant-by-pollutant evaluation of each pollutant of concern is described
in section VI.C.3. of this Fact Sheet.
E. Other Plans, Policies and Regulations
1. The discharge authorized herein and the treatment and storage facilities
associated with the discharge of treated municipal wastewater, except for
discharges of residual sludge and solid waste, are exempt from the requirements
of Title 27, California Code of Regulations (CCR), section 20005 et seq (hereafter
Title 27). The exemption, pursuant to Title 27 CCR section 20090(a), is based on
the following:
a. The waste consists primarily of domestic sewage and treated effluent;
b. The waste discharge requirements are consistent with water quality objectives;
and
c. The treatment and storage facilities described herein are associated with a
municipal wastewater treatment plant.
IV.
RATIONALE FOR EFFLUENT LIMITATIONS AND DISCHARGE SPECIFICATIONS
Effluent limitations and toxic and pretreatment effluent standards established pursuant to
sections 301 (Effluent Limitations), 302 (Water Quality Related Effluent Limitations), 304
(Information and Guidelines), and 307 (Toxic and Pretreatment Effluent Standards) of the
CWA and amendments thereto are applicable to the discharge.
The CWA mandates the implementation of effluent limitations that are as stringent as
necessary to meet water quality standards established pursuant to state or federal law [33
U.S.C., §1311(b)(1)(C); 40 CFR 122.44(d)(1)]. NPDES permits must incorporate
Attachment F – Fact Sheet
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CITY OF TRACY
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discharge limits necessary to ensure that water quality standards are met. This
requirement applies to narrative criteria as well as to criteria specifying maximum
amounts of particular pollutants. Pursuant to federal regulations, 40 CFR 122.44(d)(1)(i),
NPDES permits must contain limits that control all pollutants that “are or may be
discharged at a level which will cause, have the reasonable potential to cause, or
contribute to an excursion above any state water quality standard, including state
narrative criteria for water quality.” Federal regulations, 40 CFR 122.44(d)(1)(vi), further
provide that “[w]here a state has not established a water quality criterion for a specific
chemical pollutant that is present in an effluent at a concentration that causes, has the
reasonable potential to cause, or contributes to an excursion above a narrative criterion
within an applicable State water quality standard, the permitting authority must establish
effluent limits.”
The CWA requires point source dischargers to control the amount of conventional, nonconventional, and toxic pollutants that are discharged into the waters of the United States.
The control of pollutants discharged is established through effluent limitations and other
requirements in NPDES permits. There are two principal bases for effluent limitations in
the Code of Federal Regulations: 40 CFR 122.44(a) requires that permits include
applicable technology-based limitations and standards; and 40 CFR 122.44(d) requires
that permits include WQBELs to attain and maintain applicable numeric and narrative
water quality criteria to protect the beneficial uses of the receiving water where numeric
water quality objectives have not been established. The Basin Plan, page IV-17.00,
contains an implementation policy, “Policy for Application of Water Quality Objectives,”
that specifies that the Central Valley Water Board “will, on a case-by-case basis, adopt
numerical limitations in orders which will implement the narrative objectives.” This Policy
complies with 40 CFR 122.44(d)(1). With respect to narrative objectives, the Central
Valley Water Board must establish effluent limitations using one or more of three
specified sources, including: (1) USEPA’s published water quality criteria, (2) a proposed
state criterion (i.e., water quality objective) or an explicit state policy interpreting its
narrative water quality criteria (i.e., the Central Valley Water Board’s “Policy for
Application of Water Quality Objectives”)(40 CFR 122.44(d)(1)(vi)(A), (B) or (C)), or (3) an
indicator parameter.
The Basin Plan includes numeric site-specific water quality objectives and narrative
objectives for toxicity, chemical constituents, discoloration, radionuclides, and tastes and
odors. The narrative toxicity objective states: “All waters shall be maintained free of toxic
substances in concentrations that produce detrimental physiological responses in human,
plant, animal, or aquatic life.” (Basin Plan at III-8.00) The Basin Plan states that material
and relevant information, including numeric criteria, and recommendations from other
agencies and scientific literature will be utilized in evaluating compliance with the
narrative toxicity objective. The narrative chemical constituents objective states that
waters shall not contain chemical constituents in concentrations that adversely affect
beneficial uses. At minimum, “…water designated for use as domestic or municipal
supply (MUN) shall not contain concentrations of chemical constituents in excess of the
maximum contaminant levels (MCLs)” in Title 22 of CCR. The Basin Plan further states
that, to protect all beneficial uses, the Central Valley Water Board may apply limits more
stringent than MCLs. The narrative tastes and odors objective states: “Water shall not
Attachment F – Fact Sheet
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CITY OF TRACY
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NPDES NO. CA0079154
contain taste- or odor-producing substances in concentrations that impart undesirable
tastes or odors to domestic or municipal water supplies or to fish flesh or other edible
products of aquatic origin, or that cause nuisance, or otherwise adversely affect beneficial
uses.”
A. Discharge Prohibitions
1. Prohibition III.A (No discharge of treated wastewater at locations other than
that described in this Order). This prohibition is based on Water Code section
13260 that requires filing of a report of waste discharge (ROWD) before discharges
can occur. The Discharger submitted a ROWD for the discharges described in this
Order; therefore, discharges not described in this Order are prohibited.
2. Prohibition III.B (No bypasses or overflow of untreated wastewater, except
under the conditions at CFR Part 122.41(m)(4)). As stated in section I.G of
Attachment D, Standard Provisions, this Order prohibits bypass from any portion of
the treatment facility. Federal regulations, 40 CFR 122.41(m), define “bypass” as
the intentional diversion of waste streams from any portion of a treatment facility.
This section of the federal regulations, 40 CFR 122.41(m)(4), prohibits bypass
unless it is unavoidable to prevent loss of life, personal injury, or severe property
damage. In considering the Regional Water Board’s prohibition of bypasses, the
State Water Board adopted a precedential decision, Order WQO 2002-0015, which
cites the federal regulations, 40 CFR 122.41(m), as allowing bypass only for
essential maintenance to assure efficient operation.
3. Prohibition III.C (No controllable condition shall create a nuisance). This
prohibition is based on Water Code section 13050 that requires water quality
objectives established for the prevention of nuisance within a specific area. The
Basin Plan prohibits conditions that create a nuisance.
4. Prohibition III.D (No inclusion of pollutant free wastewater shall cause
improper operation of the Facility’s systems). This prohibition is based on CFR
Part 122.41 et seq. that requires the proper design and operation of treatment
facilities. The Discharger has proposed to reduce its salinity loading to the Delta
through operation of a desalination plant, which would result in the return of
pollutant free wastewater to the Facility. Prohibition III.D does not prohibit the
return of pollutant free wastewater from a desalination plant.
B. Technology-Based Effluent Limitations
1. Scope and Authority
Section 301(b) of the CWA and implementing USEPA permit regulations at
40 CFR 122.44 require that permits include conditions meeting applicable
technology-based requirements at a minimum, and any more stringent effluent
limitations necessary to meet applicable water quality standards. The discharge
authorized by this Order must meet minimum federal technology-based
requirements based on Secondary Treatment Standards at 40 CFR Part 133.
Attachment F – Fact Sheet
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CITY OF TRACY
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Regulations promulgated in 40 CFR 125.3(a)(1) require technology-based effluent
limitations for municipal Dischargers to be placed in NPDES permits based on
Secondary Treatment Standards or Equivalent to Secondary Treatment Standards.
The Federal Water Pollution Control Act Amendments of 1972 (PL 92-500)
established the minimum performance requirements for POTWs [defined in section
304(d)(1)]. Section 301(b)(1)(B) of that Act requires that such treatment works
must, as a minimum, meet effluent limitations based on secondary treatment as
defined by the USEPA Administrator.
Based on this statutory requirement, USEPA developed secondary treatment
regulations, which are specified in 40 CFR Part 133. These technology-based
regulations apply to all municipal wastewater treatment plants and identify the
minimum level of effluent quality attainable by secondary treatment in terms of 5day biochemical oxygen demand (BOD5), total suspended solids (TSS), and pH.
2. Applicable Technology-Based Effluent Limitations
a. BOD5 and TSS. Federal regulations, 40 CFR Part 133, establish the minimum
weekly and monthly average level of effluent quality attainable by secondary
treatment for BOD5 and TSS. Tertiary treatment is necessary to protect the
beneficial uses of the receiving stream and the final effluent limitations for
BOD5 and TSS are based on the technical capability of the tertiary process.
BOD5 is a measure of the amount of oxygen used in the biochemical oxidation
of organic matter. The secondary and tertiary treatment standards for BOD5
and TSS are indicators of the effectiveness of the treatment processes. The
principal design parameter for wastewater treatment plants is the daily BOD5
and TSS loading rates and the corresponding removal rate of the system. In
applying 40 CFR Part 133 for weekly and monthly average BOD5 and TSS
limitations, the application of tertiary treatment processes results in the ability to
achieve lower levels for BOD5 and TSS than the secondary standards currently
prescribed; the 30-day average BOD5 and TSS limitations have been revised to
10 mg/L, which is technically based on the capability of a tertiary system. In
addition to the average weekly and average monthly effluent limitations, a daily
maximum effluent limitation for BOD5 and TSS is included in the Order to
ensure that the treatment works are not organically overloaded and operate in
accordance with design capabilities. In addition, 40 CFR 133.102, in describing
the minimum level of effluent quality attainable by secondary treatment, states
that the 30-day average percent removal shall not be less than 85 percent. If
85 percent removal of BOD5 and TSS must be achieved by a secondary
treatment plant, it must also be achieved by a tertiary (i.e., treatment beyond
secondary level) treatment plant. This Order contains a limitation requiring an
average of 85 percent removal of BOD5 and TSS over each calendar month.
b. Flow. The Facility is currently designed to provide a tertiary level of treatment
for up to a design flow of 10.8 mgd. The Discharger is expanding its capacity
through a four-phased expansion. Phase 1 has been constructed and included
an upgrade to tertiary treatment with a design capacity of 10.8 mgd. Phase 2
Attachment F – Fact Sheet
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CITY OF TRACY
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has a design capacity of 12 mgd, Phase 3 has a design capacity of 13.6 mgd,
and Phase 4 has a design capacity of 16 mgd. Therefore, this Order includes
average dry weather discharge flow effluent limits ranging from 10.8 mgd to 16
mgd based on the applicable design flows for the Facility.
c. pH. The secondary treatment regulations at 40 CFR Part 133 also require that
pH be maintained between 6.0 and 9.0 standard units.
Summary of Technology-based Effluent Limitations
Discharge Point No. 001 and Discharge Point 002
Table F-4.
Summary of Technology-based Effluent Limitations
Parameter
Units
mgd
mg/L
Average
Weekly
-15
mg/L
10
15
20
--
--
Standard
Units
--
--
--
6.0
9.0
Flow
o
BOD 5-day 20 C
Total Suspended
Solids
pH
2
1
2
Effluent Limitations
Maximum Instantaneous
Daily
Minimum
1
10.8 - 16
-20
--
Average
Monthly
-10
Instantaneous
Maximum
---
Based on an existing permitted flow of 10.8 mgd. Flow capacity will increase with construction of Phases 2, 3 and 4.
More stringent water quality-based effluent limits have been implemented for pH.
C. Water Quality-Based Effluent Limitations (WQBELs)
1. Scope and Authority
Section 301(b) of the CWA and 40 CFR 122.44(d) require that permits include
limitations more stringent than applicable federal technology-based requirements
where necessary to achieve applicable water quality standards. This Order
contains requirements, expressed as a technology equivalence requirement, more
stringent than secondary treatment requirements that are necessary to meet
applicable water quality standards. The rationale for these requirements, which
consist of tertiary treatment or equivalent requirements or other provisions, is
discussed in section IV.C.3.c.x of this Fact Sheet.
40 CFR 122.44(d)(1)(i) mandates that permits include effluent limitations for all
pollutants that are or may be discharged at levels that have the reasonable
potential to cause or contribute to an instream exceedance of an applicable water
quality standard, including numeric and narrative objectives within a standard.
Where reasonable potential has been established for a pollutant, but there is no
numeric criterion or objective for the pollutant, WQBELs must be established using:
(1) USEPA criteria guidance under CWA section 304(a), supplemented where
necessary by other relevant information; (2) an indicator parameter for the pollutant
of concern; or (3) a calculated numeric water quality criterion, such as a proposed
state criterion or policy interpreting the state’s narrative criterion, supplemented
with other relevant information, as provided in 40 CFR 122.44(d)(1)(vi).
Attachment F – Fact Sheet
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CITY OF TRACY
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The process for determining reasonable potential and calculating WQBELs when
necessary is intended to protect the designated uses of the receiving water as
specified in the Basin Plan, and achieve applicable water quality objectives and
criteria that are contained in other state plans and policies, or any applicable water
quality criteria contained in the CTR and NTR.
2. Applicable Beneficial Uses and Water Quality Criteria and Objectives
The Basin Plan designates beneficial uses, establishes water quality objectives,
and contains implementation programs and policies to achieve those objectives for
all waters addressed through the plan. In addition, the Basin Plan implements
State Water Board Resolution No. 88-63, which established state policy that all
waters, with certain exceptions, should be considered suitable or potentially
suitable for municipal or domestic supply.
The Basin Plan on page II-1.00 states: “Protection and enhancement of existing
and potential beneficial uses are primary goals of water quality planning…” and
with respect to disposal of wastewaters states that “...disposal of wastewaters is
[not] a prohibited use of waters of the State; it is merely a use which cannot be
satisfied to the detriment of beneficial uses.”
The federal CWA section 101(a)(2), states: “it is the national goal that wherever
attainable, an interim goal of water quality which provides for the protection and
propagation of fish, shellfish, and wildlife, and for recreation in and on the water be
achieved by July 1, 1983.” Federal Regulations, developed to implement the
requirements of the CWA, create a rebuttable presumption that all waters be
designated as fishable and swimmable. Federal Regulations, 40 CFR sections
131.2 and 131.10, require that all waters of the State regulated to protect the
beneficial uses of public water supply, protection and propagation of fish, shell fish
and wildlife, recreation in and on the water, agricultural, industrial and other
purposes including navigation. Section 131.3(e), 40 CFR, defines existing
beneficial uses as those uses actually attained after 28 November 1975, whether
or not they are included in the water quality standards. Federal Regulation, 40
CFR section 131.10 requires that uses be obtained by implementing effluent
limitations, requires that all downstream uses be protected and states that in no
case shall a state adopt waste transport or waste assimilation as a beneficial use
for any waters of the United States.
a. Receiving Water and Beneficial Uses. The beneficial uses of the
Sacramento-San Joaquin Delta, including Old River downstream of the
discharge, as identified in Table II-1 of the Basin Plan are municipal and
domestic supply (MUN), agricultural supply (AGR), agricultural stock watering,
industrial process water supply (PRO), industrial service supply (IND), water
contact recreation (REC1), other non-contact water recreation (REC2), warm
freshwater aquatic habitat (WARM), cold freshwater aquatic habitat (COLD),
migration of aquatic organisms (MIGR) both warm and cold habitats, warm
spawning habitat (SPWN), wildlife habitat (WILD), commercial and sport fishing
(COMM), and navigation (NAV). The beneficial uses of the underlying
Attachment F – Fact Sheet
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CITY OF TRACY
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ORDER R5-2012-0115
NPDES NO. CA0079154
groundwater are municipal and domestic (MUN), industrial service (IND),
industrial process (PRO) and agricultural supply (AGR). Thus, beneficial uses
applicable to Old River are described as follows:
Table F-5.
Discharge
Point
Basin Plan Beneficial Uses
Receiving Water
Name
001, 002*
Old River
Beneficial Use(s)
Existing uses from Table II-1 of the Basin Plan:
Municipal and domestic supply (MUN);
agricultural supply and stock watering (AGR);
industrial process water supply (PROC),
industrial service supply (IND);
water contact recreation (REC-1);
other non-contact water recreation (REC-2);
warm freshwater aquatic habitat (WARM);
cold freshwater aquatic habitat (COLD);
warm and cold fish migration habitat (MIGR);
warm spawning habitat (SPAWN);
wildlife habitat (WILD);
commercial and sport fishing (COMM)
and navigation (NAV).
Potential uses from Table II-1 of the Basin Plan:
None
Intermittent uses from Section II of the Basin Plan:
None
Suitable uses from State Water Board Resolution No. 88-63:
Municipal and domestic supply (MUN).
*Future outfall proposed for Facility expansion, expected 2015.
b. Effluent and Ambient Background Data. The reasonable potential analysis
(RPA), as described in section IV.C.3 of this Fact Sheet, was based on data
since tertiary upgrades, from August 2008 through December 2011, which
includes effluent and ambient background data submitted in the SMRs, eSMRs,
and the Report of Waste Discharge (ROWD). When determining reasonable
potential for constituents using alternate data periods, it will be discussed in the
Fact Sheet (IV.C.3.).
c. Assimilative Capacity/Mixing Zone. The issues of dilution credits and mixing
zones are complex. Subsection i. summarizes the flow management of the
San Joaquin River (SJR) and the Bay Delta Plan, Subsection ii. discusses the
flow dynamics of Old River, Subsection iii. reviews the history of available flow
data, Subsection iv. discusses the existing hydrodynamic and water quality
models, Subsection v. discusses available mixing zone guidance, Subsection
vi. provides evaluation of available dilution credits for compliance with human
health criteria, and Subsection vii. discusses issues related to regulatory
compliance for dilution credits and mixing zones.
i.
Delta Operations, Bay-Delta Plan, and CALFED. The Water Quality
Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta
Estuary (Bay-Delta Plan) was adopted in May 1995 by the State Water Board
Attachment F – Fact Sheet
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and was revised in December 2006. The Bay-Delta Plan identifies the
beneficial uses of the estuary and includes objectives for flow, salinity, and
endangered species protection. The Bay-Delta Plan is reviewed periodically
in compliance with CWC section 13240 and federal CWA section 303(c).
In December 1999 and March 2000, the State Water Board adopted and
revised Water Rights Decision 1641 (D-1641) as part of the State Water
Board’s implementation of the Bay-Delta Plan. Many of the objectives in the
Bay-Delta Plan are best implemented by making changes in the flow of water
or in the operation of facilities that move water. Accordingly, this decision
amends certain water rights by assigning responsibilities to the persons or
entities holding those rights to help meet the objectives.
ii. South Delta/Old River Hydrodynamics. The responsibility for meeting
certain objectives in the South Delta is currently placed with the Department
of Water Resources (DWR) and the United States Bureau of Reclamation
(USBR) through D-1641. To meet these objectives, USBR controls the San
Joaquin River flow at Vernalis and DWR utilizes temporary barriers in the
south Delta through the South Delta Temporary Barriers Program, instituted
in 1991. The South Delta Temporary Barriers Program provides temporary
measures to mitigate flow, water quality, water availability, and the protection
of migrating San Joaquin River salmon. This project is ongoing until
permanent flow control structures are installed as part of the South Delta
Improvements Program.
The South Delta Temporary Barriers Program is comprised of temporary
barriers that are installed at the Head of Old River, Middle River, Grant Line
Canal, and Old River near Tracy. The Head of Old River (HOR) barrier
restricts flow from entering Old River. The HOR barrier was historically a
physical barrier installed in the spring and fall. In the spring, the HOR barrier
is principally a fish barrier and helps to reduce fishery impacts caused by the
Central Valley Project and the State Water Project. The spring installation of
the HOR barrier reduces entrainment of emigrating juvenile San Joaquin fallrun Chinook salmon in the southern Delta. The spring HOR barrier is no
longer a physical barrier. It is Bio-Acoustic Fish Fence (BAFF). The BAFF
uses a combination of fish-deterring sound from underwater speakers, air
bubbles, and light, to deter juvenile salmon and steelhead from entering Old
River, while allowing water to pass through the barrier. In the fall, the HOR
barrier is still a physical barrier and is installed to maintain flow rates in the
SJR thereby improving dissolved oxygen conditions in the Stockton Deep
Water Ship Channel.
The Grant Line Canal, Middle River, and Old River barriers are agricultural
barriers. These are intended to primarily benefit agricultural water users in
the south Delta. The agricultural barriers allow incoming tides to flow
upstream while restricting downstream flow. These barriers reduce tidally
caused flow reversals in the South Delta. The agricultural barriers are
Attachment F – Fact Sheet
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CITY OF TRACY
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installed to reduce salinity in the South Delta in an effort to meet the D-1641
salinity objectives. The barriers also increase water levels and circulation
patterns for local agricultural diversions. Flow conditions in Old River in the
vicinity of the discharge are affected by San Joaquin River flows, barrier
operations, and state and federal pumping operations from the State Water
Project and Central Valley Project. Additionally, the discharge is located in a
tidal zone. River flow moves upstream during the incoming or flood tide,
while downstream flows occur during the outgoing or ebb tide. Multiple
dosing of the receiving water with effluent occurs as the tide moves the water
column upstream and downstream past the point of discharge. The complex
dynamics of the stream flow, the tidal flows, the barrier operations, and the
state and federal pumping operations must be considered in an evaluation of
the available dilution for the discharge.
Flow conditions in Old River in the vicinity of the discharge are affected by
San Joaquin River flows, barrier operations, and state and federal pumping
operations from the State Water Project and Central Valley Project.
Additionally, the discharge is located in a tidal zone. River flow moves
upstream during the incoming or flood tide, while downstream flows occur
during the outgoing or ebb tide. Multiple dosing of the receiving water with
effluent occurs as the tide moves the water column upstream and
downstream past the point of discharge. The complex dynamics of the
stream flow, the tidal flows, the barrier operations, and the state and federal
pumping operations must be considered in an evaluation of the available
dilution for the discharge.
The flow of diluting water at the point of discharge varies with the tidal cycle.
Typically, as net river flow drops, at some point in the tidal cycle the incoming
tide balances against the downstream river flow resulting in river flow
stagnation and very little dilution of effluent. Below this net river flow, the
direction of the river flow reverses with incoming tides resulting in short
periods of time with zero net river flows. Additionally, with flow reversals,
some volume of river water is multiple dosed with the effluent as the river
flows downstream past the discharge, reverses, moves upstream past the
discharge a second time, then again reverses direction and passes the
discharge point a third time as it moves down the river. A particular volume of
river water may move back and forth, past the discharge point many times
due to tidal action, each time receiving an additional load of wastewater. This
is exacerbated with the barriers installed in the South Delta. The barriers
minimize inflow from the San Joaquin River and restrict downstream flows.
Therefore, flows while the barriers are in place are primarily tidal, since the
HOR barrier directs the majority of San Joaquin River flows north towards
Stockton. In addition, the agricultural barriers allow flood tides through but
the ebb tides are restricted. This maintains water levels for irrigation, but
reduces downstream flow in Old River.
Attachment F – Fact Sheet
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CITY OF TRACY
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iii. Historical Receiving Water Flow Data. Real-time flow monitoring data for
Old River in the vicinity of the discharge is not available.
However, flow data in the area are available from the United States
Geological Survey (USGS) San Joaquin River (SJR) flow monitoring station
at Vernalis, upstream of Head of Old River. SJR flow data from 1923 to the
present are available from the Vernalis station. These flow data are not
directly representative of that in Old River due to great variations that can
occur with barrier operations and Delta withdrawals. However, the data are
useful for determining critical low flow periods in the region.
The Discharger has not installed a real-time monitoring station in the vicinity
of the outfall to provide continuous monitoring of flow direction and velocity.
Real-time monitoring would provide a more accurate assessment of dilution.
iv. Water Quality Models. Water quality dilution studies have been provided by
the Discharger to support permit and CEQA requirements. Carollo Engineers
prepared a dilution study for the Discharger titled Dilution Study and Water
Quality Attainability Assessment, April 1999. The Carollo study includes
dilution modeling by Flow Science Incorporated. Larry Walker Associates
(LWA) prepared a dilution study for the Discharger titled Water Quality
Analysis of Surface Water Discharge, 2001. The LWA study includes dilution
modeling by Resource Management Associates (RMA).
Dilution Study and Water Quality Attainability Assessment, April 1999 (Carollo
Engineers). The Carollo Engineers study includes a dilution analysis and
river flow analysis utilizing the Fischer-Delta Model (FDM) to generate
average seasonal dilution values. The FDM is a proprietary computer model
used to simulate the hydrodynamics of the entire Delta. The study utilized 5.9
mgd for the effluent discharge rate and 20-year historical Delta inflow and
outflow data were utilized to generate monthly average daily flows at the point
of discharge. The model was calibrated with a rubidium tracer study
conducted in September and November 1996. Several deficiencies are found
in the model that causes uncertainty in the accuracy of the results.

The FDM model was calibrated during a wet water year hydrological
classification with temporary barriers only partially installed. The
extrapolation of the calibrated model from a wet water year with partial
barrier installation to a critically dry water year with all barriers installed
creates uncertainty that was not addressed in the study. Furthermore,
calibration alone is not adequate to determine the predictive capability of a
model for a particular receiving water. Validation and sensitivity analyses
are necessary to determine if the model is predictively valid. Without
validation testing, the calibrated model remains a description of the
conditions defined by the calibrated data set.

The model stated that average conditions were utilized, and failed to
present additional information as to the error, uncertainty, sensitivity, or
Attachment F – Fact Sheet
F-23
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
limitations of the site-specific model over the range of conditions
considered in the study.

Modeling was carried out with the condition that the downstream
agricultural barriers were in place during the summer and the HOR fish
barrier was in place in the spring and fall. The model did not anticipate the
scenario where all barriers were installed, which greatly restricts river flow
and tidal influence. This scenario has occurred several times, most
recently in May and October 2001, October 2002, October 2003, and
October 2004.

The model only used 5.9 mgd for the effluent discharge when the Report
of Waste Discharge requests a discharge of 16 mgd.

The study did not consider the Mountain House Wastewater Treatment
Facility located approximately 8 miles downstream of the outfall. Mountain
House is projected to discharge 5.4 mgd of tertiary treated wastewater to
Old River at build out.

The calculated dilution was based on the results of nested models. The
calculated net Delta outflow was input into the FDM to calculate the flow,
which was used to estimate the dilution. The study failed to discuss the
confidence level in the model outputs or how the variable inputs affected
the estimated final dilution (e.g. error, sensitivity, uncertainty, etc.).
Water Quality Analysis of Surface Water Discharge, 2001 (Larry Walker
Associates). A water quality analysis was performed by Larry Walker
Associates (LWA), as part of the CEQA process for the expansion of the
Facility, to evaluate the impacts of the increased discharge on Old River.
LWA developed the report titled, Water Quality Analysis of Surface Water
Discharge, October 2001, which used modeling performed by Resource
Management Systems, Inc. (Analysis of the Fate and Water Quality Impacts
of the City of Tracy Discharge, May 15, 2001). The water quality analysis and
modeling report are included in the October 2001 Tracy Wastewater
Treatment Plant Expansion Draft Environmental Impact Report.
The USEPA approved CORMIX model was used to evaluate initial dilution in
the vicinity of the diffuser and define the mixing zones. Computed tidally
averaged minimum monthly average velocities, flows, and depths were used
in the near-field analysis for temperature, ammonia, and other sensitive
parameters. Model sensitivity analysis indicated that the initial dilution is
dominated by the high exit velocity of the diffusers relative to the low current
velocities and the temperature differences in the receiving stream.
The far field analysis utilized the Link Node hydrodynamic model to simulate
the long-term transport and fate of a discharge. It uses monthly averaged
hydrologic data from the DWR-SIM model covering the 1922 to 1995
hydrologic year period. The model was utilized to calculate the effluent
fraction and the change in dissolved oxygen (DO) concentrations at various
Attachment F – Fact Sheet
F-24
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
locations in the South Delta. The simulation was run with four different Delta
configurations; (1) no barriers, (2) HOR barrier only, (3) agricultural barriers
only, and (4) permanent barriers. The model was calibrated using stage and
flow data from April 1997, a wet hydrologic water year, with the assumption
that the Grant Line Canal (GLC) barrier was not installed.
Several deficiencies are found in the study that causes uncertainty in the
accuracy of the results.
CORMIX is not designed for discharges to tidally influenced receiving waters,
whereas the tidal environment in Old River is significant. The study
recognizes that “tidal action causes reverse flows and prolonged periods of
slake water (several hours) at low river flows”. This results in the receiving
water being multiple-dosed with effluent. The study did not discuss the
uncertainty in the near-field model results due to the multiple-dosing. The
study did not consider the Mountain House Wastewater Treatment Facility
located approximately 8 miles downstream of the outfall. Mountain House is
projected to discharge 5.4 mgd of tertiary treated wastewater to Old River in
the near future.
The far-field water quality analysis did not evaluate the Delta configuration of
all temporary barriers installed (HOR and agricultural barriers). It assumed
the agricultural barriers are installed through September. However, recent
configurations (2001-2004) have the agricultural barriers installed until the
middle of November, which coincides with installation of the Head of Old
River fish barrier from October through November. This configuration results
in the lowest likely flows in Old River at the point of discharge.
v. Regulatory Guidance for Dilution Credits and Mixing Zones. The
Discharger has requested mixing zones and dilution credits for compliance
with human carcinogen water quality criteria. The Central Valley Water Board
has the discretion to accept or deny mixing zones and dilution credits. The
CWA directs states to adopt water quality standards to protect the quality of
its waters. USEPA’s current water quality standards regulation authorizes
states to adopt general policies, such as mixing zones, to implement state
water quality standards (40 CFR section 122.44 and section 122.45). The
USEPA allows states to have broad flexibility in designing its mixing zone
policies. Primary policy and guidance on determining mixing zone and
dilution credits is provided by the Policy for Implementation of Toxics
Standards for Inland Surface Waters, Enclosed Bays and Estuaries of
California (State Implementation Policy or SIP) and the Basin Plan. If no
procedure applies in the SIP or the Basin Plan, then the Regional Water
Board may use the USEPA Technical Support Document for Water QualityBased Toxics Control (EPA/505/2-90-001) (TSD).
The TSD defines a mixing zone as follows, “…a mixing zone is an area where
an effluent discharge undergoes initial dilution and is extended to cover the
secondary mixing in the ambient waterbody. A mixing zone is an allocated
Attachment F – Fact Sheet
F-25
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
impact zone where water quality criteria can be exceeded as long as acutely
toxic conditions are prevented.”3 The SIP provides guidance on mixing zones
and dilution credits in establishing water quality-based effluent limitations.
Water quality criteria and objectives must be met throughout a water body
except within a mixing zone. All mixing zones shall be as small as practicable
and must meet specific conditions. The allowance of mixing zones by the
Central Valley Water Board is discretionary and can be granted parameterby-parameter and/or type of criteria (e.g., acute or chronic aquatic life
criteria).
For non-priority pollutant constituents the allowance of mixing zones by the
Central Valley Water Board is discussed in the Basin Plan, Policy for
Application of Water Quality Objectives, which states in part, “In conjunction
with the issuance of NPDES and storm water permits, the Regional Board
may designate mixing zones within which water quality objectives will not
apply provided the discharger has demonstrated to the satisfaction of the
Regional Board that the mixing zone will not adversely impact beneficial uses.
If allowed, different mixing zones may be designated for different types of
objectives, including, but not limited to, acute aquatic life objectives, chronic
aquatic life objectives, human health objectives, and acute and chronic whole
effluent toxicity objectives, depending in part on the averaging period over
which the objectives apply. In determining the size of such mixing zones, the
Regional Board will consider the applicable procedures and guidelines in the
EPA’s Water Quality Standards Handbook and the [TSD]. Pursuant to EPA
guidelines, mixing zones designated for acute aquatic life objectives will
generally be limited to a small zone of initial dilution in the immediate vicinity
of the discharge.”4
For priority pollutants the SIP supersedes the Basin Plan mixing zone
provisions. Section 1.4.2 of the SIP states, in part, “…with the exception of
effluent limitations derived from TMDLs, in establishing and determining
compliance with effluent limitations for applicable human health, acute aquatic
life, or chronic aquatic life priority pollutant criteria/objectives or the toxicity
objective for aquatic life protection in a basin plan, the Regional Board may
grant mixing zones and dilution credits to dischargers ... The applicable
priority pollutant criteria and objectives are to be met throughout a water body
except within any mixing zone granted by the Regional Board. The allowance
of mixing zones is discretionary and shall be determined on a discharge-bydischarge basis. The Regional Board may consider allowing mixing zones
and dilution credits only for discharges with a physically identifiable point of
discharge that is regulated through an NPDES permit issued by the Regional
Board.” (emphasis added)5
3
4
5
TSD, Glossary
Basin Plan, page IV-16.00
SIP, pg. 15
Attachment F – Fact Sheet
F-26
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Both federal and state guidance include similar mixing zone conditions, the
SIP conditions are as follows:
“A mixing zone shall be as small as practicable. The following conditions
must be met in allowing a mixing zone: (emphasis added)
A: A mixing zone shall not:
(1)
compromise the integrity of the entire water body;
(2)
cause acutely toxic conditions to aquatic life passing through the
mixing zone;
(3)
restrict the passage of aquatic life;
(4)
adversely impact biologically sensitive or critical habitats, including,
but not limited to, habitat of species listed under federal or State
endangered species laws;
(5)
produce undesirable or nuisance aquatic life;
(6)
result in floating debris, oil, or scum;
(7)
produce objectionable color, odor, taste, or turbidity;
(8)
cause objectionable bottom deposits;
(9)
cause nuisance;
(10) dominate the receiving water body or overlap a mixing zone from
different outfalls; or
(11) be allowed at or near any drinking water intake. A mixing zone is not
a source of drinking water. To the extent of any conflict between this
determination and the Sources of Drinking Water Policy (Resolution
No. 88-63), this SIP supersedes the provisions of that policy.”
Section 1.4.2.1 of the SIP establishes the authority for the Central Valley Water
Board to consider dilution credits based on the mixing zone conditions in a
receiving water. Section 1.4.2.1 in part states:
“The dilution credit, D, is a numerical value associated with the mixing
zone that accounts for the receiving water entrained into the discharge.
The dilution credit is a value used in the calculation of effluent limitations
(described in Section 1.4). Dilution credits may be limited or denied on a
pollutant-by-pollutant basis, which may result in a dilution credit for all,
some, or no priority pollutants in the discharge.” (emphasis added)
The mixing zone is thus an administrative construct defined as an area around
the outfall that may exceed water quality objectives, but is otherwise protective
of the beneficial uses. Dilution is defined as the amount of mixing that has
occurred at the edge of this mixing zone under critical conditions, thus
protecting the beneficial uses at the concentration and for the duration and
Attachment F – Fact Sheet
F-27
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
frequency required.
vi. Evaluation of Available Dilution for Priority Pollutant Human Health
Criteria. The human health-based criteria for carcinogens, other than arsenic,
are based on safe levels for lifetime exposure and dilution is based on the
harmonic mean flow of the receiving water. In determining the available
receiving water dilution for compliance with human carcinogen criteria, the
SIP, section 1.4.2.1 requires that the harmonic mean of the receiving water
flow be compared against the arithmetic mean of the effluent flow of the
observed discharge period. However, direct Old River flow measurements do
not exist over the required period.
The Final Environmental Impact Report (EIR) for the Facility expansion
includes a short discussion of the harmonic mean flows. Table 2-9 of the
Final EIR includes a table of modeled harmonic mean flows based on the
DWR-SIM model. However, insufficient information is provided to determine
how the modeled flows were calculated. No information regarding the model
inputs has been provided in the Final EIR, and the accuracy of the modeled
flows cannot be verified.
The Discharger subsequently re-evaluated the harmonic mean flows and
available dilution using DWRs Delta Simulation Model 2 (DSM2), which was
used in the development of the draft Environmental Impact
Statement/Environment Impact Report (EIS/R) for the South Delta
Improvements Program (SDIP). Reasonable worst-case assumptions were
used for the model inputs, which are outlined in a technical memorandum
prepared by CH2M Hill for the Discharger, dated 3 April 2006, and in more
detail in Appendix D of the draft EIS/R.
Modeling was performed for a 16-year period, from 1975-1991, with
reasonable worst-case assumptions for the operation of SDIP’s operable
gates. The estimated daily harmonic mean flow was 549 cfs in Old River,
near the discharge. When excluding the wet years of 1982 and 1985, the
estimated daily harmonic mean flow was 492 cfs. The Discharger has
requested an increase in design flow to 16 mgd. Therefore, using the
estimated harmonic mean flow, excluding the wet years, and the future
design flow, the maximum allowable harmonic dilution is 20:1.
DSM2, which has been used extensively for the South Delta Improvement
Project, was also used to model the Tracy discharge to evaluate the salinity
impacts of the discharge. Several factors influence the flow and dilution in the
South Delta, including barrier operations, San Joaquin River (SJR) flow,
Central Valley Project and State Water Project export pumping, delta tides,
etc. During development of the previous permit a stakeholder group was
formed that included representatives from the City of Tracy, Mountain House
Community Services District, South Delta Water Agency, California
Sportfishing Protection Alliance, DWR, and the Central Valley Water Board to
Attachment F – Fact Sheet
F-28
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
develop appropriate scenarios for running the DSM2 model. The model was
run under reasonable worst-case conditions and was used to predict the
effluent volume fraction or effluent “finger printing” in the receiving water at
given locations. The daily average wastewater volume fractions and the 15minute flow and stage within the river channels were estimated at several
select locations. The DWR modelers recommended evaluating the model
output data on a minimum monthly average basis. This was recommended
because several inputs to the model were set constant, such as SJR flow,
agricultural inflow/outflow, and wastewater discharge rates. Therefore, the
monthly average outputs are likely to be more accurate than shorter
averaging periods (e.g., daily or weekly).
Although the intended use of the model was to evaluate the salinity impacts,
the model output is also appropriate for determining the amount of human
health dilution and the size of the human health mixing zone. Adverse human
health effects from carcinogens are based on long-term exposure (e.g.,
drinking 2 liters per day for 70 years), and the CTR criteria are based on a 30day averaging period therefore, the monthly average model outputs are
appropriate. The permit allows a dilution of 20:1 for human carcinogens
based on the harmonic mean flow in Old River of 492 cfs. Using the
reasonable worst-case modeling scenarios, DSM2 estimated the flow in Old
River upstream of the discharge to be in the same range as the harmonic
mean flow used to calculate the human carcinogen dilution credit. The
average Old River flow estimated by the DSM2 model was 505 cfs with high
exports and 491 cfs with low exports.
With a dilution credit of 20:1, the effluent volume fraction would be
approximately 5%. As shown in Table F-6 below, an effluent fraction of 5%
occurs 1 mile downstream of the discharge. Therefore, the human carcinogen
mixing zone extends no more than 1 mile downstream of the discharge. Old
River in the vicinity of the discharge is tidal and experiences reverse flows.
Based on the model output, the human carcinogen mixing zone extends less
than 0.5 miles upstream of the discharge. Modeling nodes closer to the
discharge were not modeled, so it is not possible to determine the exact
location of the upstream edge of the mixing zone. However, even if it were the
full 0.5 miles upstream the impacts would be insignificant, because there are
no drinking water or agricultural intakes within the mixing zone. The nearest
drinking water intakes are the CVP and SWP, which are approximately 10
miles downstream of the discharge. Thus, a dilution credit of 20:1 for human
carcinogens is appropriate and reasonable. Human health carcinogen criteria
dilution credits have been used in the calculation of the WQBELs for
chlorodibromomethane, dichlorobromomethane, and
bis(2-ethylhexyl)phthalate.
Attachment F – Fact Sheet
F-29
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
Table F-6.
ORDER R5-2012-0115
NPDES NO. CA0079154
Maximum Rolling 30-Day Average Effluent Volume Fractions (% Effluent)
16 mgd Discharge
Permanent Barriers Installed
High
Exports
Low
Exports
Old River 0.5 mi. Upstream of Outfall
0.5
0.4
0.5 miles upstream of outfall
Old River 1 mi. Downstream of Outfall
5.0
4.5
1 mile downstream of outfall
Old River at Tracy Rd
0.1
2.9
4 miles downstream of outfall
Grant Line Canal at Tracy Rd
4.3
4.6
2 miles downstream of outfall
Grant Line Canal at barrier
3.5
3.8
8 miles downstream of outfall
Channel Near CVP Pumps
0.5
2.0
10 miles downstream of outfall
Clifton Court Forebay (SWP Pumps)
0.0
0.2
10 miles downstream of outfall
Approx. Distance from Outfall
Chlorodibromomethane and Dichlorobromomethane. For
chlorodibromomethane and dichlorobromomethane, a 20:1 dilution credit was
used in the calculation of WQBELs in this Order. In this case, the Central
Valley Water Board finds the WQBELs in this Order require the Facility to
implement BPTC for these constituents and the human health carcinogen
criteria mixing zone is as small as practicable.
Bis(2-ethylhexyl)phthalate. For bis(2-ethylhexyl)phthalate, the WQBELs
based on a 20:1 dilution credit are an average monthly effluent limit (AMEL)
and maximum daily effluent limit (MDEL) of 30 µg/L and 92 µg/L, respectively.
Section 1.4.2.2 of the SIP requires that mixing zones are as small as
practicable. Section 1.4.2.2.B of the SIP, in part states, “The RWQCB shall
deny or significantly limit a mixing zone and dilution credits as necessary to
protect beneficial uses, meet the conditions of this Policy, or comply with
other regulatory requirements.” Based on existing Facility performance, the
Facility can meet WQBELs calculated using a dilution credit of 7.5:1 (i.e.,
AMEL of 12 µg/L and MDEL of 49 µg/L), which correlates to a significantly
smaller mixing zone. Based on modeling by the discharger this level of
dilution would occur in the zone of initial dilution that would extend a
maximum of 150 feet of the outfall. This represents a mixing zone that is as
small as practicable for this Facility and that fully complies with the SIP.
Furthermore, the Central Valley Water Board finds that granting of the full
dilution credits could allocate an unnecessarily large portion of the receiving
water’s assimilative capacity for bis(2-ethylhexyl)phthalate and could violate
the Antidegradation Policy. Although the Antidegradation Policy does not
apply within a mixing zone, the allowance of a mixing zone allows an increase
in the discharge of pollutants. Therefore, when a mixing zone and dilution
credits are allowed, it is necessary to ensure the discharge complies with the
Antidegradation Policy outside the mixing zone. The Antidegradation Policy
requires that any activity which produces a waste or increased volume or
concentration of waste which discharges to existing high quality waters is
Attachment F – Fact Sheet
F-30
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
required to meet waste discharge requirements that result in BPTC, which in
this case for bis(2-ethylhexyl)phthalate is, at minimum, existing facility
performance. Allowing the full dilution credit would allow the Discharger to
increase its loading of bis(2-ethylhexyl)phthalate to the Old River and reduce
the treatment and/or control of the pollutant. Allowing the Discharger to
reduce the level of treatment and/or control would not comply with the BPTC
requirements of the Antidegradation Policy.
In this case, the Central Valley Water Board finds this Order includes
requirements that ensure the Facility is providing BPTC for these constituents
and the human health carcinogen criteria mixing zones are as small as
practicable.
vii. Regulatory Compliance for Dilution Credits and Mixing Zones. To fully
comply with all applicable laws, regulations and policies of the State, Central
Valley Water Board approved a mixing zone and the associated dilution
credits, shown in Table F-6, based on the following:

Mixing zones are allowed under the SIP provided all elements contain
in Section 1.4.2.2 are met. Based on the mixing zone study conducted
by the Discharger the Central Valley Water Board has determined that
these factors are met.

Section 1.4.2.2.of the SIP requires mixing zones to be as small as
practicable. Based on the mixing zone study conducted by the
Discharger the Central Valley Water Board has determined the mixing
zones are as small as practicable.

In accordance with Section 1.4.2.2 of the SIP, the Central Valley Water
Board has determined the mixing zones are as small as practicable,
will not compromise the integrity of the entire water body, restrict the
passage of aquatic life, dominate the water body or overlap existing
mixing zones from different outfalls. The mixing zones are small
relative to the large size of the receiving water, are not at or near a
drinking water intake, and do not overlap a mixing zone from a different
outfall.

The Central Valley Water Board is allowing mixing zones for human
carcinogen criteria only and has determined allowing such mixing
zones will not cause acutely toxic conditions to aquatic life passing
through the mixing zones.

The Central Valley Water Board has determined the discharge will not
adversely impact biologically sensitive or critical habitats, including, but
not limited to, habitat of species listed under the federal or State
endangered species laws, because the mixing zones are for human
carcinogen criteria only, are relatively small, and acutely toxic
conditions will not occur in the mixing zones. The discharge will not
Attachment F – Fact Sheet
F-31
CITY OF TRACY
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ORDER R5-2012-0115
NPDES NO. CA0079154
produce undesirable or nuisance aquatic life, result in floating debris,
oil, or scum, produce objectionable odor, taste, or turbidity, cause
objectionable bottom deposits, or cause nuisance, because the Order
establishes end-of-pipe effluent limitations (e.g., for ammonia, BOD5,
and TSS) and discharge prohibitions to prevent these conditions from
occurring.

As required by the SIP, in determining the extent of or whether to allow
mixing zones and dilution credits, the Central Valley Water Board has
considered the presence of pollutants in the discharge that are
carcinogenic, mutagenic, teratogenic, persistent, bioaccumulative, or
attractive to aquatic organisms, and concluded that the allowance of
the mixing zones and dilution credits are adequately protective of the
beneficial uses of the receiving water.

The Central Valley Water Board has determined the mixing zones
comply with the SIP for priority pollutants.

The mixing zone study indicates the maximum allowed dilution factor
for CTR human carcinogen criteria to be 20:1. Section 1.4.2.2.B of the
SIP, in part states, “The RWQCB shall deny or significantly limit a
mixing zone and dilution credits as necessary to protect beneficial
uses, meet the conditions of this Policy, or comply with other regulatory
requirements.” The Central Valley Water Board has determined the
full dilution factor of 20:1 is not needed or necessary for
bis(2-ethylhexyl)phthalate and the Facility is capable of achieving
compliance based on a dilution factor of 7.5:1.

The Central Valley Water Board has determined that for
bis(2-ethylhexyl)phthalate allowing a dilution factor that exceeds those
allowed in this Order would not comply with the State Anti-degradation
Policy for receiving waters outside the allowable mixing zone. The
State Water Board established California’s antidegradation policy in
State Water Board Resolution No. 68-16. Resolution No. 68-16
incorporates the federal antidegradation policy and requires that
existing quality of waters be maintained unless degradation is justified
based on specific findings. Item 2 of Resolution 68-16 states:
“Any activity which produces or may produce a waste or increased
volume or concentration of waste and which dischargers or proposed
to discharge to existing high quality waters will be required to meet
waste discharge requirements which will result in the best practicable
treatment or control of the discharge necessary to assure that (a) a
pollution or nuisance will not occur and (b) the highest water quality
consistent with maximum benefit to the people of the State will be
maintained.”
Attachment F – Fact Sheet
F-32
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
The effluent limitations established in the Order for
bis(2-ethylyhexyl)phthalate that have been adjusted based on a
dilution credit of 7.5:1 were developed based on performance of the
Discharger’s current wastewater treatment capabilities. Therefore, the
Central Valley Water Board determined the effluent limitations required
by this Order will result in the Discharger implementing best practicable
treatment or control of the discharge necessary to assure that pollution
or nuisance will not occur and the highest water quality consistent with
maximum benefit to the people of the State will be maintained. The
Central Valley Water Board also determined the Discharger will be in
immediate compliance with the effluent limitations,
The Central Valley Water Board also determined establishing effluent
limitations for bis(2-ethylyhexyl)phthalate that have been adjusted
using a dilution credit of 7.5:1 is consistent with Section 1.4.2.2.B of
the SIP that requires the Central Valley Water Board shall deny or
significantly limit a mixing zone and dilution credits as necessary to
comply with other regulatory requirements.

Therefore, the Central Valley Water Board has determined the effluent
limitations established in the Order for bis(2-ethylyhexyl)phthalate that
have been developed using a dilution credit of 7.5:1 are appropriate
and necessary to comply with the Basin Plan, SIP, Federal antidegradation regulations and Resolution 68-16.
d. Conversion Factors. The CTR contains aquatic life criteria for arsenic,
cadmium, chromium III, chromium VI, copper, lead, nickel, silver, and zinc
which are presented in dissolved concentrations. USEPA recommends
conversion factors to translate dissolved concentrations to total concentrations.
The default USEPA conversion factors contained in Appendix 3 of the SIP were
used to convert the applicable dissolved criteria to total recoverable criteria.
There have been no approved studies to evaluate discharge-specific metal
translators for the discharge to Old River. Therefore, default USEPA
translators have been used for reasonable potential analysis and effluent
limitation derivation for metals. Where default USEPA translators are not
available, a translator of 1.0 has been used.
e. Hardness-Dependent CTR Metals Criteria. The California Toxics Rule and
the National Toxics Rule contain water quality criteria for seven metals that vary
as a function of hardness. The lower the hardness the lower the water quality
criteria. The metals with hardness-dependent criteria include cadmium, copper,
chromium III, lead, nickel, silver, and zinc.
Attachment F – Fact Sheet
F-33
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
This Order has established the criteria for hardness-dependent metals based
on the reasonable worst-case ambient hardness as required by the SIP6, the
CTR7 and State Water Board Order WQO 2008-0008 (City of Davis). The SIP
and the CTR require the use of “receiving water” or “actual ambient” hardness,
respectively, to determine effluent limitations for these metals. (SIP, § 1.2;
40 CFR § 131.38(c)(4)) The CTR does not define whether the term “ambient,”
as applied in the regulations, necessarily requires the consideration of
upstream as opposed to downstream hardness conditions. Therefore, where
reliable, representative data are available, the hardness value for calculating
criteria can be the downstream receiving water hardness, after mixing with the
effluent (Order WQO 2008-0008, p. 11). The Central Valley Water Board thus
has considerable discretion in determining ambient hardness (Id., p.10).
As discussed below, scientific literature provides a reliable method for
calculating protective hardness-dependent CTR criteria, considering all
discharge conditions. This methodology produces hardness-dependent CTR
criteria based on the reasonable worst-case downstream ambient hardness
that ensure these metals do not cause receiving water toxicity under any
downstream receiving water condition. Under this methodology, the Central
Valley Water Board considers all hardness conditions that could occur in the
ambient downstream receiving water after the effluent has mixed with the water
body8. This ensures that effluent limitations are fully protective of aquatic life in
all areas of the receiving water affected by the discharge under all flow
conditions, at the fully mixed location, and throughout the water body including
at the point of discharge into the water body.
i.
Conducting the Reasonable Potential Analysis (RPA). The SIP in
Section 1.3 states, “The RWQCB shall…determine whether a discharge
may: (1) cause, (2) have a reasonable potential to cause, or (3) contribute
to an excursion above any applicable priority pollutant criterion or
objective.” Section 1.3 provides a step-by-step procedure for conducting
the RPA. The procedure requires the comparison of the Maximum
Effluent Concentration (MEC) and Maximum Ambient Background
Concentration to the applicable criterion that has been properly adjusted
for hardness. Unless otherwise noted, for the hardness-dependent CTR
metals criteria the following procedures were followed for properly
adjusting the criterion for hardness when conducting the RPA.
a) The SIP requires water quality-based effluent limitations (WQBELs) if
the MEC is equal to or exceeds the applicable criterion, adjusted for
6
7
8
The SIP does not address how to determine the hardness for application to the equations for the protection of
aquatic life when using hardness-dependent metals criteria. It simply states, in Section 1.2, that the criteria
shall be properly adjusted for hardness using the hardness of the receiving water.
The CTR requires that, for waters with a hardness of 400 mg/L (as CaCO 3), or less, the actual ambient
hardness of the surface water must be used. It further requires that the hardness values used must be
consistent with the design discharge conditions for design flows and mixing zones.
All effluent discharges will change the ambient downstream metals concentration and hardness. It is not
possible to change the metals concentration without also changing the hardness.
Attachment F – Fact Sheet
F-34
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
hardness. For comparing the MEC to the applicable criterion, the “fully
mixed” reasonable worst-case downstream ambient hardness was
used to adjust the criterion. In this evaluation the portion of the
receiving water affected by the discharge is analyzed. For hardnessdependent criteria, the hardness of the effluent has an impact on the
determination of the applicable criterion in areas of the receiving water
affected by the discharge. Therefore, for comparing the MEC to the
applicable criterion, the reasonable worst-case downstream ambient
hardness was used to adjust the criterion. For this situation it is
necessary to consider the hardness of the effluent in determining the
applicable hardness to adjust the criterion. The procedures for
determining the applicable criterion after proper adjustment using the
reasonable worst-case downstream ambient hardness is outlined in
subsection ii, below.
b) The SIP requires WQBELs if the receiving water is impaired upstream
(outside the influence) of the discharge, i.e., if the Maximum Ambient
Background Concentration of a pollutant exceeds the applicable
criterion, adjusted for hardness9. For comparing the Maximum
Ambient Background Concentration to the applicable criterion, the
reasonable worst-case upstream ambient hardness was used to adjust
the criteria. This is appropriate, because this area is outside the
influence of the discharge. Since the discharge does not impact the
upstream hardness, the effect of the effluent hardness was not
included in this evaluation.
ii.
Calculating Water Quality-Based Effluent Limitations. The remaining
discussion in this section relates to the development of WQBELs when it
has been determined that the discharge has reasonable potential to cause
or contribute to an exceedance of the CTR hardness-dependent metals
criteria in the receiving water.
A 2006 Study10 developed procedures for calculating the effluent
concentration allowance (ECA)11 for CTR hardness-dependent metals.
The 2006 Study demonstrated that it is necessary to evaluate all
discharge conditions (e.g. high and low flow conditions) and the hardness
and metals concentrations of the effluent and receiving water when
determining the appropriate ECA for these hardness-dependent metals.
This method is superior to relying on downstream receiving water samples
alone because it captures all possible mixed conditions in the receiving
water. Both receiving water and effluent hardness vary based on flow and
other factors, but the variability of receiving water and effluent hardness is
9
The pollutant must also be detected in the effluent.
Emerick, R.W.; Borroum, Y.; & Pedri, J.E., 2006. California and National Toxics Rule Implementation and
Development of Protective Hardness Based Metal Effluent Limitations. WEFTEC, Chicago, Ill.
11
The ECA is defined in Appendix 1 of the SIP (page Appendix 1-2). The ECA is used to calculate WQBELs in
accordance with Section 1.4 of the SIP.
10
Attachment F – Fact Sheet
F-35
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
sometimes independent. Using a calculated hardness value ensures that
the Central Valley Water Board considers all possible mixed downstream
values that may result from these two independent variables. Relying on
receiving water sampling alone is less likely to capture all possible mixed
downstream conditions.
The equation describing the total recoverable regulatory criterion, as
established in the CTR12, is as follows:
CTR Criterion = WER x (em[ln(H)]+b)
(Equation 1)
Where:
H = hardness (as CaCO3)13
WER = water-effect ratio
m, b = metal- and criterion-specific constants
In accordance with the CTR, the default value for the WER is 1. A WER
study must be conducted to use a value other than 1. The constants “m”
and “b” are specific to both the metal under consideration, and the type of
total recoverable criterion (i.e., acute or chronic). The metal-specific
values for these constants are provided in the CTR at paragraph (b)(2),
Table 1.
The equation for the ECA is defined in Section 1.4, Step 2, of the SIP and
is as follows:
ECA = C
(when C ≤ B)14
(Equation 2)
Where:
C = the priority pollutant criterion/objective, adjusted for
hardness (see Equation 1, above)
B = the ambient background concentration
The 2006 Study demonstrated that the relationship between hardness and
the calculated criteria is the same for some metals, so the same
procedure for calculating the ECA may be used for these metals. The
same procedure can be used for chronic cadmium, chromium III, copper,
nickel, and zinc. These metals are hereinafter referred to as “Concave
Down Metals”. “Concave Down” refers to the shape of the curve
represented by the relationship between hardness and the CTR criteria in
Equation 1. Another similar procedure can be used for determining the
12
40 CFR § 131.38(b)(2).
For this discussion, all hardness values are in mg/L as CaCO 3.
14
The 2006 Study assumes the ambient background metals concentration is equal to the CTR criterion (i.e. C ≤
B)
13
Attachment F – Fact Sheet
F-36
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
ECA for acute cadmium, lead, and acute silver, which are referred to
hereafter as “Concave Up Metals”.
ECA for Chronic Cadmium, Chromium III, Copper, Nickel, and Zinc –
For Concave Down Metals (i.e., chronic cadmium, chromium III, copper,
nickel, and zinc) the 2006 Study demonstrates that when the effluent is in
compliance with the CTR criteria and the upstream receiving water is in
compliance with the CTR criteria, any mixture of the effluent and receiving
water will always be in compliance with the CTR criteria15. The 2006
Study proves that regardless of whether the effluent hardness is lower or
greater than the upstream hardness, the reasonable worst-case flow
condition is the effluent dominated condition (i.e., no receiving water
flow)16. Consequently, for Concave Down Metals, the CTR criteria have
been calculated using the downstream ambient hardness under this
condition.
The effluent hardness ranged from 200 mg/L to 348 mg/L, based on 13
samples from July 1998 to September 2011. The upstream receiving
water hardness varied from 35 mg/L to 225 mg/L, based on 42 samples
from August 2008 to December 2011, and the downstream receiving
water hardness varied from 40 mg/L to 225 mg/L, during the same period.
Under the effluent dominated condition, the reasonable worst-case
downstream ambient hardness is 200 mg/L. As demonstrated in the
example shown in Table F-7, below, using this hardness to calculate the
ECA for all Concave Down Metals will result in WQBELs that are
protective under all flow conditions, from the effluent dominated condition
to high flow condition. This example for zinc assumes the following
conservative conditions for the upstream receiving water:

Upstream receiving water always at the lowest observed upstream
receiving water hardness (i.e., 35 mg/L)

Upstream receiving water zinc concentration always at the CTR criteria
(i.e., no assimilative capacity).
Using these reasonable worst-case receiving water conditions, a simple
mass balance (as shown in Equation 3, below) accounts for all possible
mixtures of effluent and receiving water under all flow conditions.
CMIX = CRW x (1-EF) + CEff x (EF)
15
16
(Equation 3)
2006 Study, p. 5700
There are two typographical errors in the 2006 Study in the discussion of Concave Down Metals when the
effluent hardness is less than the receiving water hardness. The effluent and receiving water hardness were
transposed in the discussion, but the correct hardness values were used in the calculations. The typographical
errors were confirmed by the author of the 2006 Study, by email dated 1 April 2011, from Dr. Robert Emerick to
Mr. James Marshall, Central Valley Water Board.
Attachment F – Fact Sheet
F-37
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Where:
CMIX = Mixed concentration (e.g. metals or hardness)
CRW = Upstream receiving water concentration
CEff = Effluent concentration
EF = Effluent Fraction
In this example, for zinc, for any receiving water flow condition (high flow
to low flow), the fully-mixed downstream ambient zinc concentration is in
compliance with the CTR criteria.17
Table F-7.
Zinc ECA Evaluation
Lowest Observed Effluent Hardness
200 mg/L (as CaCO3)
Lowest Observed Upstream Receiving Water Hardness
35 mg/L (as CaCO3)
Highest Assumed Upstream Receiving Water Zinc Concentration
Zinc ECAchronic
Effluent
6
Fraction
High
1%
Flow
5%
15%
25%
50%
75%
Low
Flow
100%
1
2
3
4
5
6
2
14.0 µg/L
1
215.6 µg/L
Fully Mixed Downstream Ambient Concentration
3
4
5
Hardness
CTR Criteria
Zinc
Complies with CTR
(mg/L)
(µg/L)
(µg/L)
Criteria
Yes
36.65
51.2
50.9
Yes
43.25
58.9
57.5
Yes
59.75
77.4
74.2
Yes
76.25
95.2
90.8
Yes
117.5
137.4
132.4
Yes
158.75
177.2
174.0
Yes
200
215.6
215.6
Highest assumed upstream receiving water zinc concentration calculated using Equation 1 for
chronic criterion at a hardness of 35 mg/L.
ECA calculated using Equation 1 for chronic criterion at a hardness of 200 mg/L.
Fully mixed downstream ambient hardness is the mixture of the receiving water and effluent
hardness at the applicable effluent fraction using Equation 3.
Fully mixed downstream ambient criteria are the chronic criteria calculated using Equation 1 at
the mixed hardness.
Fully mixed downstream ambient zinc concentration is the mixture of the receiving water and
effluent zinc concentrations at the applicable effluent fraction using Equation 3.
The effluent fraction ranges from 1% at the high receiving water flow condition, to 100% at the
lowest receiving water flow condition (i.e., effluent dominated).
As discussed above, the receiving water at times contains concentrations
of copper that exceed water quality criteria associated with the hardness
17
This method considers the actual lowest observed upstream hardness and actual lowest observed effluent
hardness to determine the reasonable worst-case ambient downstream hardness under all possible receiving
water flow conditions. Table F-7 demonstrates that the receiving water is always in compliance with the CTR
criteria at the fully-mixed location in the receiving water. It also demonstrates that the receiving water is in
compliance with the CTR criteria for all mixtures from the point of discharge to the fully-mixed location.
Therefore, a mixing zone is not used for compliance.
Attachment F – Fact Sheet
F-38
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
condition previous to the discharge. The 2006 study procedures remain
applicable under these conditions. The discharge cannot cause or
contribute to a violation of water quality criteria/objectives in the receiving
water. Although metals concentrations downstream of the discharge
exceed CTR criteria, the cause of the exceedance is not due to the
discharge, it is due to the elevated metals concentrations upstream of the
discharge. Implementing the procedures of the 2006 study does not result
in an increase in toxicity downstream of the discharge, and in fact reduces
the amount of toxicity already present in the receiving water. This is
demonstrated in the example below for copper (see Table F-4a).
As shown in Table F-7a for copper, prior to the discharge the copper has
been observed to exceed water quality criteria by up to 84%. When the
receiving water contains some fraction of effluent, the percent exceedance
is reduced. The greater the amount of effluent in the receiving water, the
lower the percent exceedance, until a fully compliant state is achieved
when the effluent constitutes the entire flow. The effluent limitation
associated with copper, therefore, was sufficient to assure that the
discharge never causes or contributes to a violation of a water quality
criterion, and in fact reduces the amount of toxicity already present in the
receiving water.
Table F-7a. Copper ECA Evaluation
Lowest Observed Effluent Hardness
200 mg/L (as CaCO3)
Lowest Observed Upstream Receiving Water Hardness
35 mg/L (as CaCO3)
Highest Observed Upstream Receiving Water Copper
Concentration
Copper ECAchronic
Effluent
6
Fraction
High
0%
Flow
1%
5%
15%
25%
50%
Low
75%
Flow
100%
1
2
3
4
5
2
7.0 µg/L
1
16.9 µg/L
Fully Mixed Downstream Ambient Concentration
3
4
5
Hardness
CTR Criteria
Copper
Percent Exceeding
(mg/L)
(µg/L)
(µg/L)
Criterion
35
3.8
7.0
84%
36.65
4.0
7.1
79%
43.25
4.6
7.5
64%
59.75
6.0
8.5
41%
76.25
7.4
9.5
28%
117.5
10.7
11.9
11%
158.75
13.8
14.4
4%
200
16.9
16.9
0%
Highest assumed upstream receiving water copper concentration calculated using Equation 1
for chronic criterion at a hardness of 35 mg/L.
ECA calculated using Equation 1 for chronic criterion at a hardness of 200 mg/L.
Fully mixed downstream ambient hardness is the mixture of the receiving water and effluent
hardness at the applicable effluent fraction using Equation 3.
Fully mixed downstream ambient criteria are the chronic criteria calculated using Equation 1 at
the mixed hardness.
Fully mixed downstream ambient copper concentration is the mixture of the receiving water
Attachment F – Fact Sheet
F-39
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
6
ORDER R5-2012-0115
NPDES NO. CA0079154
and effluent copper concentrations at the applicable effluent fraction using Equation 3.
The effluent fraction ranges from 0% at the high receiving water flow condition, to 100% at the
lowest receiving water flow condition (i.e., effluent dominated).
ECA for Acute Cadmium, Lead, and Acute Silver – For Concave Up
Metals (i.e., acute cadmium, lead, and acute silver), the relationship
between hardness and the metals criteria is different than for Concave
Down Metals. The 2006 Study demonstrates that for Concave Up Metals,
the effluent and upstream receiving water can be in compliance with the
CTR criteria, but the resulting mixture may contain metals concentrations
that exceed the CTR criteria and could cause toxicity. For these metals,
the 2006 Study provides a mathematical approach to calculate the ECA
that is protective of aquatic life, in all areas of the receiving water affected
by the discharge, under all discharge and receiving water flow conditions
(see Equation 4, below).
The ECA, as calculated using Equation 4, is based on the reasonable
worst-case upstream receiving water hardness, the lowest observed
effluent hardness, and assuming no receiving water assimilative capacity
for metals (i.e., ambient background metals concentrations are at their
respective CTR criterion). Equation 4 is not used in place of the CTR
equation (Equation 1). Rather, Equation 4, which is derived using the
CTR equation, is used as a direct approach for calculating the ECA. This
replaces an iterative approach for calculating the ECA. The CTR equation
has been used to evaluate the receiving water downstream of the
discharge at all discharge and flow conditions to ensure the ECA is
protective (e.g., see Table F-8).

Effluent
 mH e - H rw  e mln H rw  b
Concentrat
ion  
ECA
H rw

Allowance
  e


mln(Hrw ) b
(Equation 4)
(Equation 4)
Where:
m, b
=
criterion specific constants (from CTR)
He
=
lowest observed effluent hardness
Hrw = reasonable worst-case upstream receiving
water hardness
An example similar to the Concave Down Metals is shown for cadmium, a
Concave Up Metal, in Table F-8, below. As previously mentioned, the
lowest effluent hardness is 200 mg/L, while the upstream receiving water
hardness ranged from 35 mg/L to 225 mg/L, and the downstream
receiving water hardness ranged from 40 mg/L to 225 mg/L.
Attachment F – Fact Sheet
F-40
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Using the procedures discussed above to calculate the ECA for all
Concave Up Metals will result in WQBELs that are protective under all
potential effluent/receiving water flow conditions (high flow to low flow) and
under all known hardness conditions, as demonstrated in Table F-8, for
cadmium.
Table F-8.
Cadmium ECA Evaluation
Lowest Observed Effluent Hardness
200 mg/L
Reasonable Worst-case Upstream Receiving Water Hardness
Reasonable Worst-case Upstream Receiving Water Cadmium
Concentration
35 mg/L
Cadmium ECAchronic
Effluent
6
Fraction
High
1%
Flow
5%
15%
25%
50%
75%
Low
Flow
100%
1
2
3
4
5
6
2
0.05 µg/L
1
4.24 µg/L
Fully Mixed Downstream Ambient Concentration
3
Hardness
4
5
Complies with
CTR Criteria
Cadmium
(mg/L)
CTR Criteria
(µg/L)
(µg/L)
(as CaCO3)
Yes
36.7
1.1
1.1
Yes
43.3
1.3
1.2
Yes
59.8
1.6
1.6
Yes
76.3
2.0
1.9
Yes
117.5
2.8
2.7
Yes
158.8
3.5
3.5
Yes
200.0
4.2
4.2
Reasonable worst-case upstream receiving water cadmium concentration calculated using
Equation 1 for chronic criterion at a hardness of 200 mg/L.
ECA calculated using Equation 4 for chronic criteria.
Fully mixed downstream ambient hardness is the mixture of the receiving water and effluent
hardness at the applicable effluent fraction.
Fully mixed downstream ambient criteria are the chronic criteria calculated using Equation 1
at the mixed hardness.
Fully mixed downstream ambient cadmium concentration is the mixture of the receiving
water and effluent lead concentrations at the applicable effluent fraction.
The effluent fraction ranges from 1% at the high receiving water flow condition, to 100% at
the lowest receiving water flow condition (i.e., effluent dominated).
As discussed above, the receiving water at times contains
concentrations of lead that exceed water quality criteria associated
with the hardness condition previous to the discharge. The 2006
study procedures remain applicable under these conditions. The
discharge cannot cause or contribute to a violation of water quality
criteria/objectives in the receiving water. Although metals
concentrations downstream of the discharge exceed CTR criteria, the
cause of the exceedance is not due to the discharge, it is due to the
elevated metals concentrations upstream of the discharge.
Implementing the procedures of the 2006 study does not result in an
increase in toxicity downstream of the discharge, and in fact reduces
Attachment F – Fact Sheet
F-41
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
the amount of toxicity already present in the receiving water. This is
demonstrated in the example below for lead (see Table F-8a).
As shown in Table F-8a for lead, prior to the discharge the lead has
been observed to exceed water quality criteria by up to 79%. When
the receiving water contains some fraction of effluent, the percent
exceedance is reduced. The greater the amount of effluent in the
receiving water, the lower the percent exceedance, until a fully
compliant state is achieved when the effluent constitutes the entire
flow. The effluent limitation associated with lead, therefore, was
sufficient to assure that the discharge never causes or contributes to a
violation of a water quality criterion, and in fact reduces the amount of
toxicity already present in the receiving water.
Table F-8a. Lead ECA Evaluation
Lowest Observed Effluent Hardness
200 mg/L (as CaCO3)
Lowest Observed Upstream Receiving Water Hardness
35 mg/L (as CaCO3)
Highest Observed Upstream Receiving Water Lead
Concentration
Lead ECAchronic
Effluent
6
Fraction
High
0%
Flow
1%
5%
15%
25%
50%
Low
75%
Flow
100%
1
2
3
4
5
6
Hardness
(mg/L)
35
36.65
43.25
59.75
76.25
117.5
158.75
200
2
µg/L
1
5.85 µg/L
Fully Mixed Downstream Ambient Concentration
3
4
5
CTR Criteria
Lead
Percent Exceeding
(µg/L)
(µg/L)
Criterion
0.84
1.50
79%
0.89
1.54
74%
1.09
1.72
57%
1.65
2.15
30%
2.25
2.59
15%
3.91
3.68
-6%
5.73
4.76
-17%
7.69
5.85
-24%
Highest assumed upstream receiving water lead concentration calculated using Equation 1 for
chronic criterion at a hardness of 35 mg/L.
ECA calculated using Equation 1 for chronic criterion at a hardness of 200 mg/L.
Fully mixed downstream ambient hardness is the mixture of the receiving water and effluent
hardness at the applicable effluent fraction using Equation 3.
Fully mixed downstream ambient criteria are the chronic criteria calculated using Equation 1 at
the mixed hardness.
Fully mixed downstream ambient copper concentration is the mixture of the receiving water
and effluent copper concentrations at the applicable effluent fraction using Equation 3.
The effluent fraction ranges from 0% at the high receiving water flow condition, to 100% at the
lowest receiving water flow condition (i.e., effluent dominated).
Attachment F – Fact Sheet
F-42
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Based on the procedures discussed above, Table F-9 lists all the CTR
hardness-dependent metals and the associated ECA used in this
Order.
Table F-9.
Summary of ECA Evaluations for
CTR Hardness-dependent Metals
ECA (μg/L, total recoverable)
CTR Metals
acute
chronic
27
17
3063
365
Cadmium
8.7
4.2
Lead
150
5.9
Nickel
843
94
Silver
6.1
--
Zinc
216
216
Copper
Chromium III
Attachment F – Fact Sheet
F-43
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Figure F-1
South Delta Temporary Barrier Locations
(1) Head Old River
(Fish Barrier)
(2) Middle River
(Agricultural Barrier)
(3) Grant Line
Canal
(Agricultural Barrier)
(4) Old River at
Tracy
Mid
dle
(Agricultural Barrier)
(2)
Grant Line Canal
Rive
O
ld
Ri
ve
r
(1)
quin
Joa
Ol
d
River
(3)
(4)
r
River
Tracy
Outfall
W
E
San
N
S
Attachment F – Fact Sheet
F-44
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
3. Determining the Need for WQBELS
a. The Central Valley Water Board conducted the reasonable potential analysis
(RPA) in accordance with section 1.3 of the SIP. Although the SIP applies
directly to the control of CTR priority pollutants, the State Water Board has held
that the Regional Water Boards may use the SIP as guidance for water qualitybased toxics control.18 The SIP states in the introduction “The goal of this
Policy is to establish a standardized approach for permitting discharges of toxic
pollutants to non-ocean surface waters in a manner that promotes statewide
consistency.” Therefore, unless otherwise specified, in this Order the RPA
procedures from the SIP were used to evaluate reasonable potential for both
CTR and non-CTR constituents based on information submitted as part of the
application, in studies, and as directed by monitoring and reporting programs.
b. Constituents with No Data or Insufficient Data. Reasonable potential
cannot be determined for the following constituents because effluent data and
ambient background concentrations are not available or insufficient.
i.
Diazinon and Chlorpyrifos
(a) WQO. A TMDL was adopted for chlorpyrifos and diazinon for the Delta
and established site-specific Basin Plan water quality objectives for
chlorpyrifos of 0.025 µg/L as a 1-hour average and 0.015 µg/L as a 4day average and diazinon of 0.16 µg/L as a 1-hour average and 0.10
µg/L as a 4-day average for Delta Waterways as specified in, Appendix
42 of Basin Plan, which includes Old River. The TMDL also
established waste load allocations for NPDES dischargers that are
included in the Basin Plan on page IV-36.03.01 and states that
“[C]ompliance with the applicable water quality objectives, load
allocations, and waste load allocations for diazinon and chlorpyrifos in
the Delta Waterways is required by December 1, 2011.”
(b) RPA Results. The Discharger has not sampled the effluent or
receiving water for diazinon or chlorpyrifos, therefore, a RPA cannot be
conducted for these constituents.
(c) WQBELs. Although an RPA cannot be conducted due to no data, in
accordance with 40 CFR 122.44(d)(1)(vii)(B), WQBELs for chlorpyrifos
and diazinon are required based on the TMDL for diazinon and
chlorpyrifos for the Delta . Therefore, this Order includes effluent limits
calculated based on the waste load allocations contained in the TMDL,
as follows:
Effluent chlorpyrifos and diazinon concentrations shall not exceed the
sum of one as defined below:
18
See Order WQO 2001-16 (Napa) and Order WQO 2004-0013 (Yuba City).
Attachment F – Fact Sheet
F-45
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
i.
ORDER R5-2012-0115
NPDES NO. CA0079154
Average Monthly Effluent Limit
SAMEL =
CD-avg
0.08
+
CC-avg
0.012
< 1.0
CD-avg = average monthly diazinon effluent concentration in μg/L
CC-avg = average monthly chlorpyrifos effluent concentration in μg/L
ii. Maximum Daily Effluent Limit
SMDEL =
CD-max
0.16
+
CC-max
0.025
< 1.0
CD-max = maximum daily diazinon effluent concentration in μg/L
CC-max = maximum daily chlorpyrifos effluent concentration in μg/L
(d) Plant Performance and Attainability. There is no expectation that
diazinon and chlorpyrifos will be in the Facility’s discharge because
these pesticides have been banned. The Central Valley Water Board
concludes that immediate compliance with these effluent limitations is
feasible.
ii.
Lead
(a) WQO. The CTR includes hardness-dependent criteria for the
protection of freshwater aquatic life for lead. These criteria for lead
are presented in dissolved concentrations. USEPA recommends
conversion factors to translate dissolved concentrations to total
concentrations. Default USEPA translators were used in this Order.
(b) RPA Results. Section IV.C.2 includes procedures for conducting the
RPA for lead. When conducting the RPA for CTR metals with
hardness-dependent criteria, the reasonable worst-case downstream
hardness is used to calculate the CTR criteria. In this case, the
applicable CTR criteria for lead based on the downstream hardness
are 5.9 µg/L (chronic) and 150 µg/L (acute), as total recoverable.
Total recoverable lead was detected but not quantified (DNQ) in three
effluent samples (see table below). Since the effluent data is DNQ,
the data is insufficient per Section 1.2 of the SIP.
Method
Detection Level
(MDL)
Reporting
Level
(RL)
Lead
Effluent
Result
10 September 2009
0.02
0.25
0.17 J
21 December 2010
0.02
0.25
0.14 J
19 July 2011
0.02
0.25
0.21 J
Sample Date
Attachment F – Fact Sheet
F-46
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
When conducting the RPA for CTR metals with hardness-dependent
criteria, the maximum ambient background concentration is compared
with the CTR criteria calculated using the lowest observed upstream
receiving water hardness. The lowest observed hardness was
35 mg/L (as CaCO3), which correlates with a chronic criterion of
0.84 μg/L and an acute criterion of 21 µg/L (as total recoverable). The
maximum observed upstream total recoverable lead was 1.5 μg/L
measured on 21 December 2010. Therefore, the maximum ambient
receiving water concentration exceeds the applicable criteria for lead.
As shown in Table F-10, an evaluation of the known situation where
metals and hardness were measured on the same day indicates that
there was an instance where the upstream receiving water exceeded
the CTR chronic criterion for lead.
Table F-10. Lead Receiving Water CTR Criteria Comparison
Lead
Sample Date
12/21/2010
RW
Hardness
(mg/L)
44.2
CTR
Chronic
Criterion
(µg/L)
1.1
RW Lead
(µg/L)
1.5
SIP Section 2.4.2 states that the Minimum Level (ML) is the lowest
quantifiable concentration in a sample based on the proper application
of all method-based analytical procedures and the absence of any
matrix interferences.
a) Required MLs are listed in Appendix 4 of the SIP. Where more than
one ML is listed in Appendix 4, the discharger may select any one of
the cited analytical methods for compliance determination. The
selected ML used for compliance determination is referred to as the
Reporting Level (RL).
b) A Reporting Level can be lower than the Minimum Level in Appendix
4 only when the discharger agrees to use a Reporting Level that is
lower than the Minimum Level listed in Appendix 4. The Central Valley
Water Board and the Discharger have no agreement to use a
Reporting Limit lower than the listed Minimum Levels.
c) SIP Section 1.2 requires that the Regional Board use all available,
valid, relevant, representative data and information, as determined by
the Regional Board, to implement the SIP. SIP Section 1.2 further
states that the Regional Board has the discretion to consider if any
data are inappropriate or insufficient for use in implementing the SIP.
Attachment F – Fact Sheet
F-47
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
d) Data reported below the Minimum Level indicates the data may not
be valid due to possible matrix interferences during the analytical
procedure.
e) Further, SIP Section 2.4.5 (Compliance Determination) supports the
insufficiency of data reported below the Minimum Level or Reporting
Level. In part it states, “Dischargers shall be deemed out of compliance
with an effluent limitation, for reporting and administrative enforcement
purposes, if the concentration of the priority pollutant in the monitoring
sample is greater than the effluent limitation and greater than or equal
to the RL.” Thus, if submitted data is below the Reporting Limit, that
data cannot be used to determine compliance with effluent limitations.
f) Data reported below the Minimum Level is not considered valid data
for use in determining Reasonable Potential. Therefore, in accordance
with Section 1.2 of the SIP, the Central Valley Water Board has
determined that data reported below the Minimum Level is
inappropriate and insufficient to be used to determine Reasonable
Potential.
g) In implementing its discretion, the Central Valley Water Board is not
finding that Reasonable Potential does not exist; rather the Central
Valley Water Board cannot make such a determination given the
invalid data. Therefore, the Central Valley Water Board will require
additional monitoring for such constituents until such time a
determination can be made in accordance with the SIP policy.
SIP Appendix 4 cites several Minimum Levels (ML) for lead. The
lowest applicable ML cited for lead is 0.5 μg/L. The Discharger used an
analytical method that was more sensitive than the minimum level
required by the SIP. The effluent results were all estimated values (i.e.,
DNQ). Therefore, the submitted effluent lead data is inappropriate and
insufficient to determine reasonable potential under the SIP.
The upstream receiving water concentration of 1.5 μg/L does exceed
the CTR chronic criterion, however, Section 1.3, Step 6 of the SIP
states that if the receiving water concentration exceeds the criteria and
the pollutant is detected in the effluent, an effluent limitation is
required. However; as discussed in detail above, insufficient effluent
data is available at this time to justify establishing an effluent limitation
for lead.
Section 1.3, Step 8 of the SIP allows the Central Valley Water Board to
require additional monitoring for a pollutant in place of an effluent
limitation if data are unavailable or insufficient. Instead of limitations,
additional monitoring has been established for lead in both the effluent
and the receiving water. Should monitoring results indicate that the
discharge has the reasonable potential to cause or contribute to an
Attachment F – Fact Sheet
F-48
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
exceedance of a water quality standard, this Order may be reopened
and modified by adding an appropriate effluent limitation.
c. Constituents with No Reasonable Potential. WQBELs are not included in
this Order for constituents that do not demonstrate reasonable potential (i.e.
constituents were not detected in the effluent or receiving water); however,
monitoring for those pollutants is established in this Order as required by the
SIP. If the results of effluent monitoring demonstrate reasonable potential, this
Order may be reopened and modified by adding an appropriate effluent
limitation.
Most constituents with no reasonable potential are not discussed in this Order.
However, the following constituents were found to have no reasonable potential
after assessment of the data:
i.
Aluminum
(a) WQO. The Code of Federal Regulations promulgated criteria for priority
toxic pollutants for California’s surface waters as part of section 131.38
Establishment of Numeric Criteria for Priority Toxic Pollutants for the State
of California (California Toxics Rule or CTR), including metals criteria.
Freshwater aquatic life criteria for metals are expressed as a function of
total hardness. However, aluminum criteria were not promulgated as part
of the CTR. Absent numeric aquatic life criteria for aluminum, WQBEL’s in
the Central Valley Water Board’s NPDES permits are based on the Basin
Plan’s narrative toxicity objective.
The Basin Plan’s Policy for Application of Water Quality Objectives
requires the Central Valley Water Board to consider, “on a case-by-case
basis, direct evidence of beneficial use impacts, all material and relevant
information submitted by the discharger and other interested parties, and
relevant numerical criteria and guidelines developed and/or published by
other agencies and organizations. In considering such criteria, the Board
evaluates whether the specific numerical criteria which are available
through these sources and through other information supplied to the
Board, are relevant and appropriate to the situation at hand and, therefore,
should be used in determining compliance with the narrative objective.”
Relevant information includes, but is not limited to the following:
(1) USEPA Guidelines for Deriving Numerical National Water Quality
Criteria for the Protection of Aquatic Organisms and Their Uses,
(2) USEPA National Recommended Ambient Water Quality Criteria
(NAWQC), (3) NAWQC–Correction, and (4) site-specific aluminum studies
conducted by dischargers within the Central Valley Region. (Basin Plan, p.
IV.-17.00; see also, 40 CFR 122.44(d)(vi).)
For aluminum, this Order implements the Basin Plan’s narrative toxicity
objective and the narrative chemical constituents objective for protection
of the aquatic life and domestic and municipal supply beneficial uses.
Attachment F – Fact Sheet
F-49
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
USEPA developed National Recommended Ambient Water Quality
Criteria (NAWQC) for protection of freshwater aquatic life for aluminum
(1988). The recommended 4-day average (chronic) and 1-hour average
(acute) criteria for aluminum are 87 µg/L and 750 µg/L, respectively, for
waters with a pH of 6.5 to 9.0. The NAWQC can be used to implement
the Basin Plan’s narrative toxicity objective. In addition, the Secondary
Maximum Contaminant Level (MCL) - Consumer Acceptance Limit for
aluminum is 200 µg/L, which implements the Basin Plan’s narrative
chemical constituents objective. Order R5-2007-0036-01 included average
monthly and maximum daily effluent limitations for aluminum based on the
NAWQC acute criterion, and annual average effluent limitations for
aluminum based on the secondary MCL.
In April 1999, USEPA released the National Recommended Water Quality
Criteria–Correction. There were no corrections to the 1988 aluminum
recommended criteria; however, USEPA recognized that they were aware
of field data indicating that many high quality waters in the U.S. contain
more than 87 μg/L aluminum, when either total recoverable or dissolved is
measured (i.e., the higher levels of aluminum did not affect beneficial
uses). Therefore, Footnote L to the National Recommended Ambient
Water Quality Criteria summary table for aluminum indicated a water
effects ratio (WER) might be appropriate for implementation of its
recommended chronic criterion for aluminum to protect aquatic organisms.
(National Recommended Water Quality Criteria–Correction (April 1999).)
Although striped bass may be present in the receiving water in the vicinity
of the discharge, monitoring data demonstrates that the study conditions
are not similar to those in the Old River, which consistently has a higher
upstream hardness, ranging from 35 to 225 mg/L and higher pH, ranging
from 6.7 to 9.1 standard units (7.6 median). Because the hardness in the
Old River is higher (which decreases the toxic effects to aquatic life) than
the water hardness values in which the criterion was developed, USEPA
advises that a WER might be appropriate to better reflect the actual
toxicity of aluminum to aquatic organisms.
In April 2005, the City of Modesto, which discharges from the Modesto
Water Quality Control Facility to the San Joaquin River upstream of the
confluence with the Old River, completed a Phase I WER for aluminum,
and on 11 November 2005, submitted the results in its Aluminum WaterEffect Ratio Study Plan. The Phase I WER study consisted of rangefinding toxicity tests, in which the NOEC, LOEC, and EC5019 were
determined for the species Daphnia magna, Ceriodaphnia dubia, and
Rainbow Trout. For this initial range-finding test, side-by-side testing with
laboratory water was not conducted. However, to obtain an estimate of the
19
The NOEC is the “no observed effect concentration”, the LOEC is the “lowest observed effect concentration”,
and the EC50 is the concentration that caused an effect to 50% of the test organisms. See Attachment A for
more detailed definitions.
Attachment F – Fact Sheet
F-50
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
potential WER for the Modesto effluent, the EC50 values determined for
the site water were divided by the Species Mean Acute Value (SMAV)
available in the aluminum criteria document according to EPA’s
streamlined WER procedure20. According to the EPA streamlined
procedure, two WERs are determined by dividing site water WERs with
both the laboratory dilution water EC50 and the SMAV; the final WER of
the sample is the lesser of the two. The estimated WERs calculated using
the SMAVs are presented in the table below:
Species
Daphnia magna
Ceriodaphnia dubia
Rainbow trout
1
Site Water EC50
for Total Al
(µg/L)
31,604
1
>11,900
1
>34,250
SMAV (µg/L
Al)
WER
38.2
1.9
10.39
827
6,263
3,296
The 2001 EPA streamlined procedures state that a “greater than” value for
the EC50 in the site water is interpreted as “equal to” in calculating the WER.
The Modesto Phase I WER study is not sufficient to calculate a WER,
however, the preliminary results confirm the conditions of San Joaquin
River are not similar to the EPA study conditions for the development of
the USEPA recommended chronic criterion. The chronic criterion is overly
stringent and is not appropriate to use to interpret the Basin Plan’s
narrative toxicity objective.
In addition, on 12 April 2007, the City of Manteca completed a Phase II
aluminum WER study for the San Joaquin River near the discharge point
for the Manteca Wastewater Quality Control Facility, which is downstream
of the City of Modesto. The Manteca Phase II WER study, which may be
used to calculate a WER for the City of Manteca’s discharge, indicated
that a WER of 22.7 can be applied to the chronic criterion for aluminum
(resulting in a chronic criterion of 22.7 x 87 µg/L = 1,975 µg/L).
In addition, monitoring data demonstrates Old River hardness
concentrations ranging from 35 mg/L to 225 mg/L and pH ranging from
6.7 to 9.1 standard units (7.6 median), are similar to conditions in the San
Joaquin River near the Manteca and Modesto discharge locations, and
are higher than conditions in which the NAWQC chronic criteria were
developed. Thus, it is unlikely that application of the chronic criterion of 87
µg/L is necessary to protect aquatic life in the Old River. Since the
characteristics of the Old River (e.g., hardness and pH) near Manteca and
Modesto are similar to those near the Facility, the results of the Manteca
WER and Modesto studies indicates that the chronic criterion
recommended by the NAWQC for aluminum is overly stringent for the Old
River.
20
USEPA. 2001. Streamlined Water-Effect Ratio Procedure for Discharges of Copper. Office of Water.
EPA-822-R-01-005. March.
Attachment F – Fact Sheet
F-51
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Based on its judgment considering the site-specific conditions of the
receiving water (e.g., hardness and pH), the Modesto Phase I WER Study,
and the Manteca Phase II WER Study, the Central Valley Water Board
finds that the NAWQC chronic criterion for aluminum is overly stringent
and should not be used to interpret the narrative toxicity objective for this
discharge. Therefore, the DPH Secondary MCL for aluminum was used to
conduct the reasonable potential analysis for aluminum.
(b) RPA Results. The maximum effluent concentration for aluminum was
49 µg/L, based on 39 samples collected between August 2008 and
December 2011. The maximum annual average effluent concentration for
aluminum was 21 µg/L based on 2009, 2010 and 2011 calendar years.
Two effluent samples collected on 5 August 2008 (290 µg/L) and
10 September 2008 (310 µg/L) were deemed to be outliers and nonrepresentative of the discharge, thus were not used in the RPA. The
figure below clearly demonstrates the two samples identified above are
not representative of the discharge, because the data points are
significantly different than the remaining dataset.
The maximum observed upstream receiving water aluminum
concentration was 1900 µg/L, and the maximum annual average
concentration was 955 µg/L, based on 15 samples collected between
July 2008 and October 2011.
Annual Average Aluminum
Concentrations
Secondary MCL
200 µg/L
Attachment F – Fact Sheet
Tracy Effluent
Old River
21 µg/L
955 µg/L
F-52
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
For priority pollutants, the SIP dictates the procedures for conducting
the RPA. Aluminum is not a priority pollutant. Therefore, the Central
Valley Water Board is not restricted to one particular RPA method.
Due to the site-specific conditions of the discharge, the Central Valley
Water Board has used its judgment in determining the appropriate
method for conducting the RPA for this non-priority pollutant
constituent.
The most stringent objective is the Secondary MCL, which is derived
from human welfare considerations (e.g., taste, odor, laundry
staining), not for toxicity. Although the receiving water contains
aluminum exceeding the Secondary MCL, the receiving water is not
listed on the 303(d) list for aluminum, and aluminum is not a
constituent of concern in the development of the Drinking Water
Policy. Additionally, the effluent aluminum is consistently less than
the concentrations in the receiving water and below the Secondary
MCL. Therefore, the Central Valley Water Board finds the discharge
does not have reasonable potential to cause or contribute to an
exceedance in the receiving water and the Facility is adequately
controlling the discharge of aluminum.
Order R5-2007-0036-01 included an annual average final effluent limit
of 200 µg/L, an AMEL of 462 µg/L, and an MDEL of 755 µg/L. Since
there is no reasonable potential these effluent limits have not been
retained in this Order. Removal of these effluent limitations is in
accordance with federal antibacksliding regulations (see section
IV.D.3 of the Fact Sheet).
ii.
Dissolved Oxygen
(a) WQO. The Basin Plan contains a numeric site-specific water quality
objective for the Delta, in the vicinity of the discharge, that requires that
dissolved oxygen (DO) concentrations shall not be reduced below
5 mg/L. Old River from the San Joaquin River to the Delta Mendota
Canal is listed on the CWA Section 303(d) list for low dissolved
oxygen.
(b) RPA Results. Based on 412 receiving water samples collected
between August 2008 through July 2012 at RSW-002 and RSW-003
(500 feet east and west of the discharge), the DO concentrations have
been consistently above the Basin Plan objective of 5 mg/L, averaging
10.2 mg/L. Of the 206 days of DO sampling, the receiving water DO
was measured below the Basin Plan objective on only four days, twice
in August 2008 and twice in July 2009. Based on the effluent sampling
for DO and oxygen-demanding substances (i.e., biochemical oxygen
demand and ammonia) the effluent discharge did not cause or
contribute to the DO violations in the receiving water. The effluent
Attachment F – Fact Sheet
F-53
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
daily average DO in the discharge during those periods was between
6.2 mg/L and 9.7 mg/L, while the effluent biochemical oxygen demand
ranged from 2.7 mg/L to 3.6 mg/L and the effluent ammonia was nondetect (<1.0 mg/L).
Based on this information, the discharge does not have reasonable
potential to cause or contribute to an exceedance of the Basin Plan DO
Objective in the receiving water. Therefore, the WQBELs for DO have
been removed in this Order. Removal of the effluent limitations is
consistent federal antibacksliding regulations and complies with state
and federal antidegradation requirements.
iii.
Iron
(a) WQO. The Basin Plan contains a site-specific numeric objective for the
Delta of 300 µg/L (maximum concentration) for iron, expressed as
dissolved metal. The Secondary MCL for iron is 300 µg/L (annual
average), expressed as total recoverable metal.
(b) RPA Results. The maximum effluent concentration for iron was
54 µg/L based on 42 samples collected between August 2008 and
December 2011. The maximum annual average effluent concentration
for iron was 28 µg/L based on 2009, 2010 and 2011 calendar years.
The maximum observed iron concentration in the receiving water was
4000 µg /L in 15 samples collected August 2008 and October 2011,
and the maximum annual average concentration was 1833 µg/L based
on 2009, 2010 and 2011 calendar years.
Iron
Basin Plan
(Delta)
Maximum Concentration
Annual Average
1
2
Secondary
MCL
Tracy
Effluent
Old River
Receiving Water
300 µg/L
--
54 µg/L
4000 µg/L
--
300 µg/L
28 µg/L
1833 µg/L
1
2
Maximum iron concentration expressed as dissolved metal.
Annual average expressed as total recoverable metal.
For priority pollutants, the SIP dictates the procedures for conducting
the RPA. Iron is not a priority pollutant. Therefore, the Central Valley
Water Board is not restricted to one particular RPA method. Due to
the site-specific conditions of the discharge, the Central Valley Water
Board has used its judgment in determining the appropriate method for
conducting the RPA for this non-priority pollutant constituent.
The most stringent objective is the Secondary MCL, which is derived
from human welfare considerations (e.g., taste, odor, laundry staining),
not for toxicity. Although the receiving water contains iron exceeding
the Secondary MCL, the receiving water is not listed as impaired on
Attachment F – Fact Sheet
F-54
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
the 303(d) list for iron, and iron is not a constituent of concern in the
development of the Drinking Water Policy. Additionally, the effluent iron
is consistently less than the concentrations in the receiving water and
below the Secondary MCL. Therefore, the Central Valley Water Board
finds the discharge does not have reasonable potential to cause or
contribute to an exceedance in the receiving water and the Facility is
adequately controlling the discharge of iron.
Since the discharge does not demonstrate reasonable potential, the
effluent limitations for iron have not been retained in this Order.
Removal of these effluent limitations is in accordance with federal
antibacksliding regulations (see section IV.D.3 of the Fact Sheet).
iv.
Manganese
(a) WQO. The Basin Plan includes a site-specific Basin Plan objective for
manganese for the Delta of 50 µg/L (maximum concentration) and the
Secondary MCL is 50 µg/L (annual average).
(b) RPA Results. The maximum effluent concentration for manganese
was 20 µg/L based on 42 samples collected between August 2008 and
December 2011. The maximum annual average effluent concentration
for manganese was 5 µg/L based on 2009, 2010 and 2011 calendar
years. The maximum observed manganese concentration in the
receiving water was 290 µg/L in 15 samples collected between August
2008 and October 2011, and the maximum annual average
concentration was 147 µg/L based on 2009, 2010 and 2011 calendar
years.
Manganese
Basin Plan
(Delta)
Secondary
MCL
Tracy
Effluent
Old River
Receiving Water
Maximum Concentration
50 µg/L
--
20 µg/L
290 µg/L
Annual Average
--
50 µg/L
5 µg/L
147 µg/L
For priority pollutants, the SIP dictates the procedures for conducting
the RPA. Manganese is not a priority pollutant. Therefore, the Central
Valley Water Board is not restricted to one particular RPA method.
Due to the site-specific conditions of the discharge, the Central Valley
Water Board has used its judgment in determining the appropriate
method for conducting the RPA for this non-priority pollutant
constituent.
The most stringent objective is the Secondary MCL, which is derived
from human welfare considerations (e.g., taste, odor, laundry staining),
not for toxicity. Although the receiving water contains manganese
Attachment F – Fact Sheet
F-55
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
exceeding the Secondary MCL, the receiving water is not listed as
impaired on the 303(d) list for manganese, and manganese is not a
constituent of concern in the development of the Drinking Water Policy.
Additionally, the effluent manganese concentrations are consistently
less than the concentrations in the receiving water and below the
Secondary MCL. Therefore, the Central Valley Water Board finds the
discharge does not have reasonable potential to cause or contribute to
an exceedance in the receiving water and the Facility is adequately
controlling the discharge of manganese.
d. Constituents with Reasonable Potential. The Central Valley Water Board
finds that the discharge has a reasonable potential to cause or contribute to an
in-stream excursion above a water quality standard for ammonia, bis(2ethylhexyl) phthalate, chlorodibromomethane, copper, dichlorobromomethane,
electrical conductivity, mercury, nitrate + nitrite, pathogens, pH, salinity and
toxicity. WQBELs for these constituents are included in this Order. A summary
of the RPA is provided in Attachment G, and a detailed discussion of the RPA
for each constituent is provided below.
i.
Ammonia
(a) WQO. The NAWQC for the protection of freshwater aquatic life for
total ammonia, recommends acute (1-hour average; criteria maximum
concentration or CMC) standards based on pH and chronic (30-day
average; criteria continuous concentration or CCC) criteria based on
pH and temperature. USEPA also recommends that the 4-day average
concentration should not exceed 2.5 times the 30-day CCC. USEPA
found that as pH increased, both the acute and chronic toxicity of
ammonia increased. Salmonids were more sensitive to acute toxicity
effects than other species. However, while the acute toxicity of
ammonia was not influenced by temperature, it was found that
invertebrates and young fish experienced increasing chronic toxicity
effects with increasing temperature. Because the Old River has a
beneficial use of cold freshwater habitat and the presence of salmonids
and early fish life stages in the Old River is well-documented, the
recommended criteria for waters where salmonids and early life stages
are present were used.
(a) RPA Results. Federal regulations at 40 C.F.R. §122.44(d)(1)(i)
requires that, “Limitations must control all pollutants or pollutant
parameters (either conventional, nonconventional, or toxic pollutants)
which the Director determines are or may be discharged at a level
which will cause, have the reasonable potential to cause, or contribute
to an excursion above any State water quality standard, including State
narrative criteria for water quality.” For priority pollutants, the SIP
dictates the procedures for conducting the RPA. Ammonia is not a
priority pollutant. Therefore, the Central Valley Water Board is not
restricted to one particular RPA method. Due to the site-specific
Attachment F – Fact Sheet
F-56
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
conditions of the discharge, the Central Valley Water Board has used
its judgment in determining the appropriate method for conducting the
RPA for this non-priority pollutant constituent.
USEPA’s September 2010 NPDES Permit Writer’s Manual, page 6-30,
states, “State implementation procedures might allow, or even require,
a permit writer to determine reasonable potential through a qualitative
assessment process without using available facility-specific effluent
monitoring data or when such data are not available…A permitting
authority might also determine that WQBELs are required for specific
pollutants for all facilities that exhibit certain operational or discharge
characteristics (e.g., WQBELs for pathogens in all permits for POTWs
discharging to contact recreational waters).” USEPA’s TSD also
recommends that factors other than effluent data should be considered
in the RPA, “When determining whether or not a discharge causes,
has the reasonable potential to cause, or contributes to an excursion of
a numeric or narrative water quality criterion for individual toxicants or
for toxicity, the regulatory authority can use a variety of factors and
information where facility-specific effluent monitoring data are
unavailable. These factors also should be considered with available
effluent monitoring data.” With regard to POTWs, USEPA
recommends that, “POTWs should also be characterized for the
possibility of chlorine and ammonia problems.” (TSD, p. 50)
The Facility is a POTW that treats domestic wastewater. Untreated
domestic wastewater contains ammonia. Nitrification is a biological
process that converts ammonia to nitrite and nitrite to nitrate.
Denitrification is a process that converts nitrate to nitrite or nitric oxide
and then to nitrous oxide or nitrogen gas, which is then released to the
atmosphere. The Discharger currently uses nitrification to remove
ammonia from the waste stream. Inadequate or incomplete nitrification
may result in the discharge of ammonia to the receiving stream.
Ammonia is known to cause toxicity to aquatic organisms in surface
waters. Discharges of ammonia in concentrations that produce
detrimental physiological responses to human, plant, animal, or aquatic
life would violate the Basin Plan narrative toxicity objective. Although
the Discharger nitrifies the discharge, inadequate or incomplete
nitrification creates the potential for ammonia to be discharged and
provides the basis for the discharge to have a reasonable potential to
cause or contribute to an in-stream excursion above the NAWQC.
Therefore, the Central Valley Water Board finds the discharge has
reasonable potential for ammonia and WQBELs are required.
(b) WQBELs. Applying 40 CFR CFR section 122.44(d)(1)(vi)(B), effluent
limitations for ammonia are included in this Order and are based on
U.S. EPA’s Ambient Water Quality Criteria for the protection of the
beneficial use of freshwater aquatic habitat. This Order contains final
Attachment F – Fact Sheet
F-57
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
AMEL and MDEL for ammonia of 1.3 mg/L and 2.1 mg/L, respectively
(See Attachment F, Table F-8 for WQBEL calculations). The use of
seasonal effluent limitations was considered due to the seasonal
variation of temperature of the effluent. However, the acute criterion,
which is not dependent on temperature, controls the effluent limitation
derivation. Therefore, for the application of the acute condition (1-hr
duration), the ammonia effluent limitations apply year-round.
Furthermore, due to periods of no flow in the receiving water, a dilution
credit cannot be granted.
The development of fixed WQBELs for ammonia can be complex due
to the variable ammonia criteria. In State Water Board WQ 2009-0003
for the City of Tracy, the State Water Board determined that the permit
lacked an adequate rationale for development of the fixed WQBELs for
ammonia using the median receiving water pH and remanded the
permit to the Central Valley Water Board to either provide sufficient
justification for the effluent limits or modify the limits. In the above
approach for determining the appropriate chronic criterion, an
assumption is made that the compliant discharge (i.e., meets ammonia
criteria) causes a non-compliant situation in the receiving water due to
changes in pH and/or temperature that result in a more stringent
chronic criterion. In this approach, the ammonia concentrations in the
effluent are assumed to remain the same downstream of the
discharge, whereas the pH and temperature change. This is a
conservative approach and is used when there is insufficient ammonia
receiving water data to determine the actual ambient ammonia
concentrations. For the City of Tracy, there is weekly ammonia
monitoring in the receiving water, along with pH and temperature
monitoring.
In a similar situation for the City of Stockton, receiving water ammonia
concentrations were compared to paired 30-day average chronic
ammonia criteria to determine if the discharge caused the receiving
water criterion to be exceeded in the receiving water. Based on the
receiving water data, the ammonia criteria were never exceeded and it
was determined that the current ammonia effluent limits were
adequately protective. In the case of Stockton where this evaluation
was used to justify current effluent limits, the permit was petitioned and
the State Water Board agreed with this approach21.
This same evaluation was conducted for the City of Tracy. Receiving
water ammonia, pH, and temperature data were evaluated since
implementation of the current ammonia effluent limits. Figure F-3,
below, shows the calculated 30-day average chronic criteria from
March 2007 thru January 2012 at R-002 and R-003, which are located
21
State Board WQ 2009-0012 for the City of Stockton Regional Wastewater Control Facility
Attachment F – Fact Sheet
F-58
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
500 feet east and west of the discharge, respectively. This period
includes the critically dry years of 2007 and 200822. As demonstrated
in the figure, the criteria fluctuate based on season due to fluctuations
in pH and temperature. The most stringent criteria occur during the
summer when the highest pH and temperature values occur.
Figure F-2
30-day Average Ammonia Criteria
7
R-003
R-002
6
5
4
3
2
1
0
Jan-07
May-08
Sep-09
Feb-11
All ammonia receiving water data has been non-detect (<1 mg/L) from
June 2007 through July 2010 and non-detect (<0.2 mg/L) from August
2010 through January 2012 (Tracy conducts weekly receiving water
monitoring for ammonia, pH, and temperature).This demonstrates that
the discharge is not causing exceedances of the ammonia criteria in
the receiving water. Therefore, based on this information, it is justified
to maintain the final effluent limits for ammonia. During each permit
renewal, the ammonia effluent limitations will be re-evaluated to ensure
they are adequately protective of the aquatic life beneficial uses.
This Order contains final AMEL and MDEL for ammonia of 1.3 mg/L
and 2.1 mg/L, respectively (See Attachment F, Table F-8 for WQBEL
calculations).
(c) Plant Performance and Attainability. Analysis of the effluent data
shows that the MEC is 3.6 µg/L, which exceeds the MDEL for
22
Water Year Hydrologic Classification Indices (http://cdec.water.ca.gov/cgi-progs/iodir/WSIHIST)
Attachment F – Fact Sheet
F-59
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
ammonia. However, the effluent ammonia concentrations have not
exceeded the MDEL of 2.1 mg/L since July 2009. The Central Valley
Water Board concludes, therefore, that immediate compliance with
these effluent limitations is feasible.
ii. Bis(2-ethylhexyl)phthalate
(a) WQO. The CTR includes a criterion of 1.8 µg/L for bis (2-ethylhexyl)
phthalate for the protection of human health for waters from which both
water and organisms are consumed.
(b) RPA Results. Bis (2-ethylhexyl) phthalate was detected 4 times out of
43 effluent samples collected between August 2008 and December
2011 at concentrations ranging from 0.76 µg/L to 12 µg/L. Bis (2ethylhexyl) phthalate was not detected in the upstream receiving water
based on 15 samples collected between July 2008 and October 2011.
The MEC of 12 µg/L could be considered an outlier as it is 6 standard
deviations from the mean, but the bis-2 detection of 2 µg/L is likely not
an outlier and exceeds the CTR criterion. Bis (2-ethylhexyl) phthalate
is a common contaminant of sample containers, sampling apparatus,
and analytical equipment, and sources of the detected bis (2ethylhexyl) phthalate may be from plastics used for sampling or
analytical equipment. The Discharger has been collecting and
analyzing bis (2-ethylhexyl) phthalate using “clean techniques” to
ensure that sample containers, sampling apparatus, and analytical
equipment are not sources of the detections. In the absence of
evidence that the source of the detected samples is laboratory error,
the Central Valley Water Board concludes that bis (2-ethylehxyl)
phthalate in the discharge has a reasonable potential to cause or
contribute to an in-stream excursion above the CTR criterion for the
protection of human health.
(c) WQBELs. As described further in section IV.C.2.c of this Fact Sheet,
assimilative capacity is available and a dilution credit of 7.5:1 is
appropriate for calculating effluent limitations for bis (2-ethylhexyl)
phthalate. Therefore, this Order establishes WQBELs for bis (2ethylhexyl) phthalate of 12 µg/L and 49 µg/L, as an AMEL and MDEL,
respectively.
(d) Plant Performance and Attainability. Analysis of the effluent data
shows that the 99.9th percentile of the data is 6.7 µg/L and the MEC is
12 µg/L. The Central Valley Water Board concludes, therefore, that
immediate compliance with these effluent limitations is feasible.
Attachment F – Fact Sheet
F-60
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
iii.
ORDER R5-2012-0115
NPDES NO. CA0079154
Chlorine, Total Residual
(a) WQO. USEPA developed NAWQC for protection of freshwater aquatic life
for chlorine residual. The recommended 4-day average (chronic) and 1hour average (acute) criteria for chlorine residual are 0.011 µg/L and
0.019 µg/L, respectively. These criteria are protective of the Basin Plan’s
narrative toxicity objective.
(b) RPA Results. Federal regulations at 40 C.F.R. §122.44(d)(1)(i) requires
that, “Limitations must control all pollutants or pollutant parameters (either
conventional, nonconventional, or toxic pollutants) which the Director
determines are or may be discharged at a level which will cause, have the
reasonable potential to cause, or contribute to an excursion above any
State water quality standard, including State narrative criteria for water
quality.” For priority pollutants, the SIP dictates the procedures for
conducting the RPA. Chlorine is not a priority pollutant. Therefore, the
Central Valley Water Board is not restricted to one particular RPA method.
Due to the site-specific conditions of the discharge, the Central Valley
Water Board has used its judgment in determining the appropriate method
for conducting the RPA for this non-priority pollutant constituent.
USEPA’s September 2010 NPDES Permit Writer’s Manual, page 6-30,
states, “State implementation procedures might allow, or even require, a
permit writer to determine reasonable potential through a qualitative
assessment process without using available facility-specific effluent
monitoring data or when such data are not available…A permitting
authority might also determine that WQBELs are required for specific
pollutants for all facilities that exhibit certain operational or discharge
characteristics (e.g., WQBELs for pathogens in all permits for POTWs
discharging to contact recreational waters).” USEPA’s TSD also
recommends that factors other than effluent data should be considered in
the RPA, “When determining whether or not a discharge causes, has the
reasonable potential to cause, or contributes to an excursion of a numeric
or narrative water quality criterion for individual toxicants or for toxicity, the
regulatory authority can use a variety of factors and information where
facility-specific effluent monitoring data are unavailable. These factors also
should be considered with available effluent monitoring data.” With regard
to POTWs, USEPA recommends that, “POTWs should also be
characterized for the possibility of chlorine and ammonia problems.” (TSD,
p. 50)
The Discharger uses chlorine for disinfection, which is extremely toxic to
aquatic organisms. Although the Discharger uses a sulfur dioxide process
to dechlorinate the effluent prior to discharge to Old River, the existing
chlorine use and the potential for chlorine to be discharged provides the
basis for the discharge to have a reasonable potential to cause or
contribute to an in-stream excursion above the NAWQC.
Attachment F – Fact Sheet
F-61
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
(c) WQBELs. The USEPA Technical Support Document for Water QualityBased Toxics Control [EPA/505/2-90-001] contains statistical methods for
converting chronic (4-day) and acute (1-hour) aquatic life criteria to
average monthly and maximum daily effluent limitations based on the
variability of the existing data and the expected frequency of monitoring.
However, because chlorine is an acutely toxic constituent that can and will
be monitored continuously, an average 1-hour limitation is considered
more appropriate than an average daily limitation. This Order contains a
4-day average effluent limitation and 1-hour average effluent limitation for
chlorine residual of 0.011 µg/L and 0.019 µg/L, respectively, based on
USEPA’s NAWQC, which implements the Basin Plan’s narrative toxicity
objective for protection of aquatic life.
(d) Plant Performance and Attainability. Based on the analysis of the
effluent, the Central Valley Water Board concludes that immediate
compliance with these effluent limitations is feasible.
iv.
Chlorodibromomethane
(a) WQO. The CTR includes a chlorodibromomethane criterion of
0.41 µg/L for the protection of human health and is based on a one-ina-million cancer risk for waters from which both water and organisms
are consumed.
(b) RPA Results. All Old River monitoring results from 17 samples
collected between July 2008 and October 2011 were below the method
detection limit; therefore, the maximum background ambient
concentration was set to the lowest of the individual reported method
detection limits, which was 0.03 µg/L.
The MEC for chlorodibromomethane was 28 µg/L, based on 58
samples collected between August 2008 and December 2011.
Therefore, the discharge has a reasonable potential to cause or
contribute to an in-stream excursion of a water quality objective and
effluent limitations are necessary.
(c) WQBELs. The ambient monitoring demonstrates the receiving water
has assimilative capacity for chlorodibromomethane. A dilution credit
for chlorodibromomethane of 20:1 has been granted, based on the
available human health dilution (see Attachment F, Section
IV.C.2.b.viii.). This Order contains final AMEL and MDEL for
chlorodibromomethane of 8 µg/L and 18 µg/L, respectively (See
Attachment H for WQBEL calculations).
(d) Plant Performance and Attainability. In 2010, the Facility installed a
water champ chemical induction mixer for the purpose of enhanced
mixing of chlorine and ammonia. The direct gas injection/mixer
resulted in a better mixing of the chemical solution that allowed
Attachment F – Fact Sheet
F-62
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
adequate control of THMs formation, chemical usage reduction, and
eliminated using a water pump to create the chemical solution which
also reduced energy usage. Since this improvement and based on
current Facility performance, it appears that the Discharger can
immediately comply with these effluent limitations.
v.
Copper
(a) WQO. The CTR includes hardness-dependent criteria for the
protection of freshwater aquatic life for copper. These criteria for
copper are presented in dissolved concentrations, as 1-hour acute
criteria and 4-day chronic criteria. USEPA recommends conversion
factors to translate dissolved concentrations to total concentrations.
Default USEPA translators (i.e., 0.96 for acute and chronic criteria)
were used for the receiving water and effluent.
The Basin Plan (BP) includes a site-specific objective for the
Sacramento-San Joaquin Delta of 10 µg/L (dissolved) as a maximum
concentration. Using the default USEPA translator, the BP objective is
10.4 µg/L (total recoverable).
Footnote 4, page 3, of the Introduction of the SIP states, “If a water
quality objective and a CTR criterion are in effect for the same priority
pollutant, the more stringent of the two applies.” The BP objective
cannot be directly compared to the CTR criteria to determine which is
the most stringent objective because they have different averaging
periods and the CTR criteria vary with hardness. In this situation, the
RPA has been conducted considering both the CTR criteria and the BP
water quality objectives.
(b) RPA Results. Section IV.C.2 of this Fact Sheet includes procedures
for conducting the RPA for hardness-dependent CTR metals, such as
copper. The CTR includes hardness-dependent criteria for copper for
the receiving water. The maximum observed upstream receiving water
copper concentration was 7 µg/L, based on 18 samples collected
between July 2008 and October 2011. The RPA was conducted using
the upstream receiving water hardness to calculate the criteria for
comparison to the maximum ambient background concentration, and
likewise using the reasonable worst-case downstream hardness to
compare the maximum effluent concentration. The table below shows
the specific criteria used for the RPA.
Attachment F – Fact Sheet
F-63
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
CTR Hardness
Dependent
Chronic Criterion
(Total Recoverable)
Receiving
Water
3.8 µg/L
Effluent
17 µg/L
Site-Specific BP
Objective
Maximum
Concentration
(Total Recoverable)
1
10.4 µg/L
7.0 µg/L
2
10.4 µg/L
5.9 µg/L
Reasonable
Potential?
(Y/N)
5
Yes
4
No
3
1
Based on lowest observed upstream hardness of 35 mg/L (as CaCO3)
Based on reasonable worst-case downstream hardness of 200 mg/L (as CaCO3)
3
Maximum ambient background concentration exceeds CTR chronic criterion, but not BP objective.
4
Maximum observed effluent copper concentration, from May 2010 through December 2011.
5
Maximum observed background receiving water copper concentration, from July 2008 through
October 2011.
2
Based on the available data, the discharge has reasonable potential to
cause or contribute to an exceedance of the CTR criterion in the
receiving water, but the discharge does not demonstrate reasonable
potential for the site-specific Basin Plan objective. Consequently,
WQBELs are required for copper.
(c) WQBELs. In accordance with the SIP, the more stringent of the two
applicable criteria, the CTR criteria and the BP objective, was used to
determine reasonable potential. Although reasonable potential was
triggered only by the CTR criteria, the resulting WQBELs that are
calculated based on the CTR criteria result in WQBELs exceeding the
BP Objective (see table below).
WQBELs
CTR Chronic
Criterion
(Aquatic Life)
Basin Plan
1
Objective
1
Average Monthly
Effluent Limit
(AMEL)
Maximum Daily
Effluent Limit
(MDEL)
15 µg/L
25 µg/L
--
10.4 µg/L
Fourth Edition of the Water Quality Control Plan (Basin Plan) for the Sacramento River and
San Joaquin River Basins, Table III-1, Copper. Applicable to the Sacramento-San Joaquin
Delta, Appendix 42 Waterways, 86. Old River.
Consequently, the WQBELs have been developed using the BP
objective resulting in a MDEL of 10.4 µg/L (total recoverable), which is
consistent with the previous Order. The SIP requires average monthly
and maximum daily effluent limits for CTR constituents. The sitespecific objective for copper is established as a maximum
concentration. Therefore, it is impracticable to calculate average
monthly effluent limitations for copper using the BP objective.
Therefore, an average monthly effluent limitation of 15 µg/L was
calculated using the CTR criteria. This Order includes a MDEL of
10.4 µg/L and an AMEL of 15 µg/L, as total recoverable copper.
Attachment F – Fact Sheet
F-64
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
(d) Plant Performance and Attainability. Based on facility performance
the Central Valley Water Board finds the Discharger can comply
immediately with these limits.
vi.
Dichlorobromomethane
(a) WQO. The CTR includes a dichlorobromomethane criterion of
0.56 µg/L for the protection of human health and is based on a one-ina-million cancer risk for waters from which both water and organisms
are consumed.
(b) RPA Results. All Old River monitoring results from 17 samples
collected between July 2008 and October 2011 were below the method
detection limit; therefore, the maximum background ambient
concentration was set to the lowest of the individual reported method
detection limits, which was 0.06 µg/L.
The MEC for dichlorobromomethane was 40 µg/L, based on 58
samples collected between August 2008 and December 2011.
Therefore, the discharge has a reasonable potential to cause or
contribute to an in-stream excursion of a water quality objective and
effluent limitations are necessary.
(c) WQBELs. The ambient monitoring demonstrates the receiving water
has assimilative capacity for dichlorobromomethane. A dilution credit
for dichlorobromomethane of 20:1 has been granted, based on the
available human health dilution (see Attachment F, Section
IV.C.2.b.viii.). This Order contains final AMEL and MDEL for
dichlorobromomethane of 11 µg/L and 29 µg/L, respectively (See
Attachment H for WQBEL calculations).
(d) Plant Performance and Attainability. In 2010, the Facility installed a
water champ chemical induction mixer for the purpose of enhanced
mixing of chlorine and ammonia. The direct gas injection/mixer
resulted in a better mixing of the chemical solution that allowed
adequate control of THMs formation, chemical usage reduction, and
eliminated using a water pump to create the chemical solution which
also reduced energy usage. Since this improvement and based on
current Facility performance, it appears that the Discharger can
immediately comply with these effluent limitations.
vii. Electrical Conductivity. (see Subsection xii. Salinity)
Attachment F – Fact Sheet
F-65
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
viii. Mercury
(a) WQO. The Basin Plan contains fish tissue objectives for all Delta
waterways listed in Appendix 43 of the Basin Plan that states, “…the
average methylmercury concentrations shall not exceed 0.08 and 0.24
mg methylmercury/kg, wet weight, in muscle tissue of trophic level 3
and 4 fish, respectively (150-500 mm total length). The average
methylmercury concentrations shall not exceed 0.03 mg
methylmercury/kg, wet weight, in whole fish less than 50 mm in
length.” The Delta Mercury Control Program contains aqueous
methylmercury waste load allocations that are calculated to achieve
the fish tissue objectives. Methylmercury reductions are assigned to
discharges with concentrations of methylmercury greater than 0.06 ng/l
(the concentration of methylmercury in water to meet the fish tissue
objectives).
The CTR contains a human health criterion (based on a threshold dose
level causing neurological effects in infants) of 50 ng/L for total
mercury for waters from which both water and aquatic organisms are
consumed. However, in 40 CFR Part 131, USEPA acknowledges that
the human health criteria may not be protective of some aquatic or
endangered species and that “…more stringent mercury limits may be
determined and implemented through use of the State’s narrative
criterion.” In the CTR, USEPA reserved the mercury criteria for
freshwater and aquatic life and may adopt new criteria at a later date.
(b) RPA Results. Section 1.3 of the SIP states, “The RWQCB shall
conduct the analysis in this section for each priority pollutant with an
applicable criterion or objective, excluding priority pollutants for
which a Total Maximum Daily Load (TMDL) has been developed,
to determine if a water quality-based effluent limitation is required in
the discharger’s permit.” (emphasis added) Although a RPA is not
required, based on the available effluent and receiving water
methylmercury data, it appears the discharge is causing or contributing
to an exceedance of the concentration of methylmercury in water to
meet the site-specific fish tissue objectives in the Basin Plan. The
maximum observed effluent methylmercury concentration was
0.2 ng/L, and the maximum ambient methylmercury concentration was
0.3 ng/L.
(c) WQBELs. The Basin Plan’s Delta Mercury Control Program includes
wasteload allocations for POTWs in the Delta, including for the
Discharger. In accordance with 40 CFR 122.44(d)(1)(vii)(B) and the
SIP, this Order contains final WQBELs for methylmercury based on the
wasteload allocation. The total calendar annual methylmercury load
shall not exceed 0.77 grams.
Attachment F – Fact Sheet
F-66
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
(d) Plant Performance and Attainability. Based on available effluent
methylmercury data, the Central Valley Water Board finds the
Discharger is unable to immediately comply with the final WQBELs for
methylmercury. Therefore, a compliance schedule in accordance with
the State Water Board’s Compliance Schedule Policy and the Delta
Mercury Control Program has been established in this Order.
ix. Nitrate and Nitrite
(a) WQO. DPH has adopted Primary MCLs for the protection of human
health for nitrite and nitrate that are equal to 1 mg/L and 10 mg/L
(measured as nitrogen), respectively. DPH has also adopted a primary
MCL of 10,000 µg/L for the sum of nitrate and nitrite, measured as
nitrogen.
USEPA has developed a primary MCL and an MCL goal of 1,000 µg/L
for nitrite (as nitrogen). For nitrate, USEPA has developed Drinking
Water Standards (10,000 µg/L as Primary MCL) and NAWQC for
protection of human health (10,000 µg/L for non-cancer health effects).
Recent toxicity studies have indicated a possibility that nitrate is toxic
to aquatic organisms.
(b) RPA Results. Federal regulations at 40 C.F.R. §122.44(d)(1)(i)
requires that, “Limitations must control all pollutants or pollutant
parameters (either conventional, nonconventional, or toxic pollutants)
which the Director determines are or may be discharged at a level
which will cause, have the reasonable potential to cause, or contribute
to an excursion above any State water quality standard, including State
narrative criteria for water quality.” For priority pollutants, the SIP
dictates the procedures for conducting the RPA. Nitrite and nitrate are
not priority pollutants. Therefore, the Central Valley Water Board is not
restricted to one particular RPA method. Due to the site-specific
conditions of the discharge, the Central Valley Water Board has used
its judgment in determining the appropriate method for conducting the
RPA for this non-priority pollutant constituent.
USEPA’s September 2010 NPDES Permit Writer’s Manual, page 6-30,
states, “State implementation procedures might allow, or even require,
a permit writer to determine reasonable potential through a qualitative
assessment process without using available facility-specific effluent
monitoring data or when such data are not available…A permitting
authority might also determine that WQBELs are required for specific
pollutants for all facilities that exhibit certain operational or discharge
characteristics (e.g., WQBELs for pathogens in all permits for POTWs
discharging to contact recreational waters).” USEPA’s TSD also
recommends that factors other than effluent data should be considered
in the RPA, “When determining whether or not a discharge causes,
has the reasonable potential to cause, or contributes to an excursion of
Attachment F – Fact Sheet
F-67
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
a numeric or narrative water quality criterion for individual toxicants or
for toxicity, the regulatory authority can use a variety of factors and
information where facility-specific effluent monitoring data are
unavailable. These factors also should be considered with available
effluent monitoring data.” With regard to POTWS, USEPA
recommends that, “POTWs should also be characterized for the
possibility of chlorine and ammonia problems.” (TSD, p. 50)
The Facility is a POTW that treats domestic wastewater. Untreated
domestic wastewater contains ammonia and this Order requires
removal of ammonia (i.e., nitrification). Nitrification is a biological
process that converts ammonia to nitrite and nitrite to nitrate.
Denitrification is a process that converts nitrate to nitrite or nitric oxide
and then to nitrous oxide or nitrogen gas, which is then released to the
atmosphere. The Discharger currently uses nitrification/denitrification
to remove ammonia, nitrite, and nitrate from the waste stream.
Inadequate or incomplete denitrification may result in the discharge of
nitrate and/or nitrite to the receiving stream. Discharges of nitrate plus
nitrite in concentrations that exceed the primary MCL would violate the
Basin Plan narrative chemical constituents objective. Although the
Discharger denitrifies the discharge, inadequate or incomplete
denitrification creates the potential for nitrate and nitrite to be
discharged and provides the basis for the discharge to have a
reasonable potential to cause or contribute to an in-stream excursion
above the primary MCL. Therefore, the Central Valley Water Board
finds the discharge has reasonable potential for nitrate plus nitrite and
WQBELs are required.
(c) WQBELs. This Order contains an AMEL for nitrate plus nitrite of
10 mg/L (total as N), based on the primary MCL. This effluent limitation
is included in this Order to assure the treatment process adequately
nitrifies and denitrifies the waste stream to protect the beneficial use of
municipal and domestic supply.
(d) Plant Performance and Attainability. Since upgrades were
completed to completely nitrify and denitrify the wastewater in August
2008, and based on the current Facility performance, it appears that
the Discharger can immediately comply with this effluent limitation.
x. Pathogens
(a) WQO. DPH has developed reclamation criteria, CCR, Division 4,
Chapter 3 (Title 22), for the reuse of wastewater. Title 22 requires that
for spray irrigation of food crops, parks, playgrounds, schoolyards, and
other areas of similar public access, wastewater be adequately
disinfected, oxidized, coagulated, clarified, and filtered, and that the
effluent total coliform levels not exceed 2.2 MPN/100 mL as a 7-day
median; 23 MPN/100 mL, not to be exceeded more than once in a 30Attachment F – Fact Sheet
F-68
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
day period; and 240 MPN/100 mL, at any time.
Title 22 also requires that recycled water used as a source of water
supply for non-restricted recreational impoundments be disinfected
tertiary recycled water that has been subjected to conventional
treatment. A non-restricted recreational impoundment is defined as
“…an impoundment of recycled water, in which no limitations are
imposed on body-contact water recreational activities.” Title 22 is not
directly applicable to surface waters; however, the Central Valley
Water Board finds that it is appropriate to apply an equivalent level of
treatment to that required by the DPH’s reclamation criteria because
the receiving water is used for irrigation of agricultural land and for
contact recreation purposes. The stringent disinfection criteria of Title
22 are appropriate since the undiluted effluent may be used for the
irrigation of food crops and/or for body-contact water recreation.
Coliform organisms are intended as an indicator of the effectiveness of
the entire treatment train and the effectiveness of removing other
pathogens.
(b) RPA Results. Federal regulations at 40 C.F.R. §122.44(d)(1)(i)
requires that, “Limitations must control all pollutants or pollutant
parameters (either conventional, nonconventional, or toxic pollutants)
which the Director determines are or may be discharged at a level
which will cause, have the reasonable potential to cause, or contribute
to an excursion above any State water quality standard, including State
narrative criteria for water quality.” For priority pollutants, the SIP
dictates the procedures for conducting the RPA. Pathogens are not
priority pollutants. Therefore, the Central Valley Water Board is not
restricted to one particular RPA method. Due to the site-specific
conditions of the discharge, the Central Valley Water Board has used
its judgment in determining the appropriate method for conducting the
RPA for this non-priority pollutant constituent.
USEPA’s September 2010 NPDES Permit Writer’s Manual, page 6-30,
states, “State implementation procedures might allow, or even require,
a permit writer to determine reasonable potential through a qualitative
assessment process without using available facility-specific effluent
monitoring data or when such data are not available…A permitting
authority might also determine that WQBELs are required for specific
pollutants for all facilities that exhibit certain operational or discharge
characteristics (e.g., WQBELs for pathogens in all permits for POTWs
discharging to contact recreational waters).” USEPA’s TSD also
recommends that factors other than effluent data should be considered
in the RPA, “When determining whether or not a discharge causes,
has the reasonable potential to cause, or contributes to an excursion of
a numeric or narrative water quality criterion for individual toxicants or
for toxicity, the regulatory authority can use a variety of factors and
Attachment F – Fact Sheet
F-69
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
information where facility-specific effluent monitoring data are
unavailable. These factors also should be considered with available
effluent monitoring data.” (TSD, p. 50)
The beneficial uses of Old River include municipal and domestic
supply, water contact recreation, and agricultural irrigation supply, and
there is, at times, less than 20:1 dilution. To protect these beneficial
uses, the Central Valley Water Board finds that the wastewater must
be disinfected and adequately treated to prevent disease. Although
the Discharger provides disinfection, inadequate or incomplete
disinfection creates the potential for pathogens to be discharged and
provides the basis for the discharge to have a reasonable potential to
cause or contribute to an exceedance of the Basin Plan’s narrative
toxicity objective. Therefore, the Central Valley Water Board finds the
discharge has reasonable potential for pathogens and WQBELs are
required.
(c) WQBELs. The method of treatment is not prescribed by this Order;
however, wastewater must be treated to a level equivalent to that
recommended by DPH. In accordance with the requirements of
Title 22, this Order includes effluent limitations for total coliform
organisms of 2.2 MPN/100 mL as a 7-day median; 23 MPN/100 mL,
not to be exceeded more than once in a 30-day period; and 240
MPN/100 mL as an instantaneous maximum. As coliform organisms
are living and mobile, it is impracticable to quantify an exact number of
coliform organisms and to establish weekly average limitations.
Instead, coliform organisms are measured as a most probable number
and regulated based on a 7-day median limitation.
In addition to coliform limitations, an operational specification for
turbidity has been included as a second indicator of the effectiveness
of the treatment process and to assure compliance with the required
level of treatment. The Title 22 tertiary treatment process, or
equivalent, is capable of reliably meeting a turbidity limitation of 2
nephelometric turbidity units (NTU) as a daily average. Failure of the
filtration system such that virus removal is impaired would normally
result in increased particles in the effluent, which result in higher
effluent turbidity. Turbidity has a major advantage for monitoring filter
performance, allowing immediate detection of filter failure and rapid
corrective action. Coliform testing, by comparison, is not conducted
continuously and requires several hours, to days, to identify high
coliform concentrations. In accordance with DPH recommendations,
this Order includes operational specifications for turbidity of 2 NTU as
a daily average; 5 NTU, not to be exceeded more than 5% of the time
within a 24-hour period; and 10 NTU as an instantaneous maximum.
Attachment F – Fact Sheet
F-70
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Final WQBELs for BOD5 and TSS are based on the technical capability
of the tertiary process, which is necessary to protect the beneficial
uses of the receiving water. BOD5 is a measure of the amount of
oxygen used in the biochemical oxidation of organic matter. The
tertiary treatment standards for BOD5 and TSS are indicators of the
effectiveness of the tertiary treatment process. The principal design
parameter for wastewater treatment plants is the daily BOD5 and TSS
loading rates and the corresponding removal rate of the system. The
application of tertiary treatment processes results in the ability to
achieve lower levels for BOD5 and TSS than the secondary standards
currently prescribed. Therefore, this Order requires AMELs for BOD5
and TSS of 10 mg/L, which is technically based on the capability of a
tertiary system. In addition to the average weekly and average
monthly effluent limitations, a daily maximum effluent limitation for
BOD5 and TSS is included in the Order to ensure that the treatment
works are not organically overloaded and operate in accordance with
design capabilities.
This Order contains effluent limitations for BOD5, total coliform
organisms, and TSS and requires a Title 22 tertiary level of treatment,
or equivalent, necessary to protect the beneficial uses of the receiving
water. The Central Valley Water Board has previously considered the
factors in Water Code section 13241 in establishing these
requirements.
(d) Plant Performance and Attainability. The Facility includes
disinfection facilities that can comply with the WQBELs. The Central
Valley Water Board concludes, therefore, that immediate compliance
with these effluent limitations is feasible.
xi.
pH
(a) WQO. The Basin Plan includes a water quality objective for surface
waters (except for Goose Lake) that the “…pH shall not be depressed
below 6.5 nor raised above 8.5.
(b) RPA Results. Federal regulations at 40 C.F.R. §122.44(d)(1)(i)
requires that, “Limitations must control all pollutants or pollutant
parameters (either conventional, nonconventional, or toxic pollutants)
which the Director determines are or may be discharged at a level
which will cause, have the reasonable potential to cause, or contribute
to an excursion above any State water quality standard, including State
narrative criteria for water quality.” For priority pollutants, the SIP
dictates the procedures for conducting the RPA. pH is not a priority
pollutant. Therefore, the Central Valley Water Board is not restricted to
one particular RPA method. Due to the site-specific conditions of the
discharge, the Central Valley Water Board has used its judgment in
determining the appropriate method for conducting the RPA for this
Attachment F – Fact Sheet
F-71
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
non-priority pollutant constituent.
USEPA’s September 2010 NPDES Permit Writer’s Manual, page 6-30,
states, “State implementation procedures might allow, or even require,
a permit writer to determine reasonable potential through a qualitative
assessment process without using available facility-specific effluent
monitoring data or when such data are not available…A permitting
authority might also determine that WQBELs are required for specific
pollutants for all facilities that exhibit certain operational or discharge
characteristics (e.g., WQBELs for pathogens in all permits for POTWs
discharging to contact recreational waters).” USEPA’s TSD also
recommends that factors other than effluent data should be considered
in the RPA, “When determining whether or not a discharge causes,
has the reasonable potential to cause, or contributes to an excursion of
a numeric or narrative water quality criterion for individual toxicants or
for toxicity, the regulatory authority can use a variety of factors and
information where facility-specific effluent monitoring data are
unavailable. These factors also should be considered with available
effluent monitoring data.” (TSD, p. 50)
The Facility is a POTW that treats domestic wastewater. Although the
Discharger has proper pH controls in place, the pH for the Facility’s
influent varies due to the nature of municipal sewage, which provides
the basis for the discharge to have a reasonable potential to cause or
contribute to an in-stream excursion above the Basin Plan’s numeric
objective for pH in the receiving water. Therefore, WQBELs for pH are
required in this Order.
(c) WQBELs. Effluent limitations for pH of 6.5 as an instantaneous
minimum and 8.5 as an instantaneous maximum are included in this
Order based on protection of the Basin Plan objectives for pH.
(d) Plant Performance and Attainability. Based on available effluent pH
data, it appears the Discharger is able to comply with these limitations.
The Central Valley Water Board concludes, therefore, that immediate
compliance with these effluent limitations is feasible.
xii. Salinity
(a) WQO. The Basin Plan contains a chemical constituent objective that
incorporates state MCLs, contains a narrative objective, and contains
numeric water quality objectives for electrical conductivity, total
dissolved solids, sulfate, and chloride. In addition, USEPA has
developed National Ambient Water Quality Criteria for chloride for the
protection of freshwater aquatic life.
Attachment F – Fact Sheet
F-72
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Table F-11. Salinity Water Quality Criteria/Objectives
Parameter
Secondary
1
MCL
BayDelta
Plan
EC (µmhos/cm)
900, 1600,
2200
700/1000
TDS (mg/L)
500, 1000,
1500
Sulfate (mg/L)
Chloride (mg/L)
1
2
3
Effluent
USEPA
NAWQC
Average
N/A
1252
N/A
N/A
728
2
909
250, 500, 600
N/A
N/A
147
150
250, 500, 600
N/A
230 4-day
860 1-hr
161
220
3
2
Maximum
1569
The secondary MCLs are stated as a recommended level, upper level, and a
short-term maximum level.
Maximum calendar annual average.
The Bay-Delta Plan includes water quality objectives at three locations in the
South Delta for EC, which includes a 14-day running average EC of
700 µmhos/cm from 1 April – 31 Aug and a 14-day running average EC of
1000 µmhos/cm from 1 September - 31 March. The State Water Board is
developing revised salinity objectives for municipal dischargers.
(1) Chloride. The secondary MCL for chloride is 250 mg/L, as a
recommended level, 500 mg/L as an upper level, and 600 mg/L as a
short-term maximum. USEPA Ambient Water Quality Criteria for
Chloride recommends acute (1-hour) and chronic (4-day) criteria for
the protection of freshwater aquatic life of 860 mg/L and 230 mg/L,
respectively.
(2) Electrical Conductivity. The secondary MCL for EC is
900 µmhos/cm as a recommended level, 1600 µmhos/cm as an upper
level, and 2200 µmhos/cm as a short-term maximum.
The Bay-Delta Plan includes water quality objectives for EC for the
South Delta in the vicinity of the discharge23. On 1 June 2011, the
Superior Court for Sacramento County entered a judgment and
peremptory writ of mandate in the matter of City of Tracy v. State
Water Resources Control Board (Case No; 34-2009-8000-392-CUWM-GDS), ruling that the South Delta salinity objectives shall not apply
to the City of Tracy and other municipal dischargers pending
reconsideration of the South Delta salinity objectives and adoption of a
proper program of implementation that includes municipal dischargers.
The State Water Board is currently considering new salinity and flow
objectives in the South Delta that will address the Court Order.
23
The Bay-Delta Plan includes water quality objectives at three locations in the South Delta for EC. The water
quality objectives are a 14-day running average EC of 700 µmhos/cm from 1 April – 31 Aug and a 14-day
running average EC of 1000 µmhos/cm from 1 September - 31 March.
Attachment F – Fact Sheet
F-73
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Therefore, at the time this Order was adopted the South Delta salinity
objectives are not applicable to the Discharger.
(3) Sulfate. The secondary MCL for sulfate is 250 mg/L as a
recommended level, 500 mg/L as an upper level, and 600 mg/L as a
short-term maximum.
(4) Total Dissolved Solids. The secondary MCL for TDS is 500 mg/L as
a recommended level, 1000 mg/L as an upper level, and 1500 mg/L as
a short-term maximum.
(b) RPA Results.
(1) Chloride. Chloride concentrations in the effluent ranged from 160
mg/L to 220 mg/L, with an average of 161 mg/L. Background
concentrations in Old River ranged from 21 mg/L to 100 mg/L, with an
average of 47 mg/L, for 4 samples collected by the Discharger from
August 2008 through July 2011. The applicable water quality objective
to implement the Basin Plan’s narrative chemical constituents objective
for salinity is the Bay-Delta Plan south Delta salinity objectives, which
are under development.
(2) Electrical Conductivity. A review of the Discharger’s monitoring
reports shows a maximum calendar annual average effluent EC of
1252 µmhos/cm, with a range from 954 µmhos/cm to 1569 µmhos/cm.
The background receiving water EC averaged 544 µmhos/cm. The
applicable water quality objective to implement the Basin Plan’s
narrative chemical constituents objective for salinity is the Bay-Delta
Plan south Delta salinity objectives.
(3) Sulfate. Sulfate concentrations in the effluent ranged from 110 mg/L
to 150 mg/L, with an average of 147 mg/L. These levels do not exceed
the secondary MCL. Background concentrations in Old River ranged
from 22 mg/L to 70 mg/L, with an average of 45 mg/L. The Discharge
does not have reasonable potential for sulfate.
(4) Total Dissolved Solids. The maximum calendar annual average TDS
effluent concentration was 728 mg/L with concentrations ranging from
569 mg/L to 909 mg/L. Background receiving water data is
unavailable. The applicable water quality objective to implement the
Basin Plan’s narrative chemical constituents objective for salinity is the
Bay-Delta Plan south Delta salinity objectives, which are under
development.
(c) WQBELs.
The State Water Board is currently revising the Bay-Delta Plan to
include salinity objectives that would be applicable to the discharge.
Attachment F – Fact Sheet
F-74
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Since the Bay-Delta Plan will include the applicable salinity objectives
to conduct the reasonable potential analysis, until completion of the
update, the reasonable potential analysis cannot be completed
properly.
Pending the Bay-Delta Plan amendment, this Order carries forward the
TDS effluent limits and salinity controls from the previous permit. This
Order includes an annual mass loading effluent limitation for TDS and
requires the Discharger to implement measures to reduce the salinity
in its discharge to Old River.
The TDS effluent limitation is carried forward from the previous Order
and is based on treatment plant performance. The TDS effluent limit
will ensure that the mass loading of salinity does not increase as the
effluent flow rate increases. In previous Order R5-2007-0036-01 an
interim TDS loading limit was established due to antidegradation
concerns. In the previous permit the Discharger requested an increase
in discharge flow from 9 MGD to 16 MGD. A condition of the increase
was that the salt loading would remain the same, which satisfied the
antidegradation requirements. The Discharger is able to maintain its
current salt loading as the discharge flows increase, because it is
expanding the use of lower salinity water supplies to support the
growth in the City of Tracy. In this Order, the TDS loading limit was
changed from an interim effluent limit to a final effluent limit. The TDS
loading limit was originally established to satisfy antidegradation
requirements, therefore, the effluent limits should be final effluent
limits. Interim effluent limits should only be included in NPDES permits
when a time schedule results in a delay in the implementation of final
effluent limits. In this case, the TDS loading limits must remain in
effect to comply with antidegradation requirements and therefore are
not interim effluent limits that will be replaced by final effluent limits at a
future date.
This Order also requires the Discharger to implement a Salinity
Reduction Plan that includes pollution prevention measures to reduce
the salinity in its discharge to Old River. The Salinity Plan must include
a pollution prevention plan for salinity in accordance with Water Code
section 13263.3(d)(3), and requires the Discharger to report on
progress in reducing salinity discharges to Old River in an effort to
meet a salinity goal of a calendar annual average 500 µmhos/cm
electrical conductivity increase over the calendar annual weighted
average EC of the City of Tracy’s water supply. The Salinity Reduction
Plan must also include measures the Discharger is taking to implement
best practicable treatment or control (BPTC) of the discharge for
salinity, describe the Discharger’s participation in CV-SALTS, and
describe the Dischargers efforts to obtain lower salinity water supplies.
Attachment F – Fact Sheet
F-75
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
xiv. Temperature
(a) WQO. The Thermal Plan requires that, “The maximum temperature
shall not exceed the natural receiving water temperature by more than
20°F.”
(b) RPA Results. Federal regulations at 40 C.F.R. §122.44(d)(1)(i)
requires that, “Limitations must control all pollutants or pollutant
parameters (either conventional, nonconventional, or toxic pollutants)
which the Director determines are or may be discharged at a level
which will cause, have the reasonable potential to cause, or contribute
to an excursion above any State water quality standard, including State
narrative criteria for water quality.” For priority pollutants, the SIP
dictates the procedures for conducting the RPA. Temperature is not a
priority pollutant. Therefore, the Central Valley Water Board is not
restricted to one particular RPA method. Due to the site-specific
conditions of the discharge, the Central Valley Water Board has used
its judgment in determining the appropriate method for conducting the
RPA for this non-priority pollutant constituent.
USEPA’s September 2010 NPDES Permit Writer’s Manual, page 6-30,
states, “State implementation procedures might allow, or even require,
a permit writer to determine reasonable potential through a qualitative
assessment process without using available facility-specific effluent
monitoring data or when such data are not available…A permitting
authority might also determine that WQBELs are required for specific
pollutants for all facilities that exhibit certain operational or discharge
characteristics (e.g., WQBELs for pathogens in all permits for POTWs
discharging to contact recreational waters).” USEPA’s TSD also
recommends that factors other than effluent data should be considered
in the RPA, “When determining whether or not a discharge causes,
has the reasonable potential to cause, or contributes to an excursion of
a numeric or narrative water quality criterion for individual toxicants or
for toxicity, the regulatory authority can use a variety of factors and
information where facility-specific effluent monitoring data are
unavailable. These factors also should be considered with available
effluent monitoring data.” (TSD, p. 50)
The Facility is a POTW that treats domestic wastewater. Domestic
wastewater is an elevated temperature waste, which provides the
basis for the discharge to have a reasonable potential to cause or
contribute to an excursion above Thermal Plan requirements.
Therefore, WQBELs for temperature are required in this Order.
(c) WQBELs. To ensure compliance with the Thermal Plan, an effluent
limitation for temperature is included in this Order.
Attachment F – Fact Sheet
F-76
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
(d) Plant Performance and Attainability. Based on existing Facility
performance it appears the Discharger can immediately comply with
the temperature effluent limits.
xv. Whole Effluent Toxicity (See Section IV.C.5)
4. WQBEL Calculations
a. This Order includes WQBELs for ammonia, copper, chlorodibromomethane,
dichlorobromomethane, bis(2-ethylhexyl)phthalate, nitrate plus nitrite (total as
N), dissolved oxygen, total residual chlorine, diazinon, chlorpyrifos, and
methylmercury. The general methodology for calculating WQBELs based on
the different criteria/objectives is described in subsections IV.C.4.b through e,
below. See Attachment H for the WQBEL calculations.
b. Effluent Concentration Allowance. For each water quality criterion/objective,
the ECA is calculated using the following steady-state mass balance equation
from Section 1.4 of the SIP:
ECA = C + D(C – B)
ECA = C
where C>B, and
where C≤B
where:
ECA
D
C
B
= effluent concentration allowance
= dilution credit
= the priority pollutant criterion/objective
= the ambient background concentration.
According to the SIP, the ambient background concentration (B) in the equation
above shall be the observed maximum with the exception that an ECA
calculated from a priority pollutant criterion/objective that is intended to protect
human health from carcinogenic effects shall use the arithmetic mean
concentration of the ambient background samples. For ECAs based on MCLs,
which implement the Basin Plan’s chemical constituents objective and are
applied as annual averages, an arithmetic mean is also used for B due to the
long-term basis of the criteria.
c. Basin Plan Objectives and MCLs. For WQBELs based on site-specific
numeric Basin Plan objectives or MCLs, the effluent limitations are applied
directly as the ECA as either an MDEL, AMEL, or average annual effluent
limitations, depending on the averaging period of the objective.
d. Aquatic Toxicity Criteria. WQBELs based on acute and chronic aquatic
toxicity criteria are calculated in accordance with Section 1.4 of the SIP. The
ECAs are converted to equivalent long-term averages (i.e. LTAacute and
LTAchronic) using statistical multipliers and the lowest LTA is used to calculate
the AMEL and MDEL using additional statistical multipliers.
Attachment F – Fact Sheet
F-77
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
e. Human Health Criteria. WQBELs based on human health criteria, are also
calculated in accordance with Section 1.4 of the SIP. The ECAs are set equal
to the AMEL and a statistical multiplier was used to calculate the MDEL.
LTAacute
AMEL  multAMEL minM A ECAacute , MC ECAchronic 
MDEL  multMDEL minM A ECAacute , MC ECAchronic 
LTAchronic
 multMDEL 
 AMEL HH
MDEL HH  
mult
AMEL 

where:
multAMEL = statistical multiplier converting minimum LTA to AMEL
multMDEL = statistical multiplier converting minimum LTA to MDEL
MA = statistical multiplier converting acute ECA to LTAacute
MC =
statistical multiplier converting chronic ECA to LTAchronic
Summary of Water Quality-Based Effluent Limitations
Discharge Point No. 001 and Discharge Point No. 002
Table F-12. Summary of Water Quality-Based Effluent Limitations
Parameter
Units
mg/L
Biochemical Oxygen
Demand (BOD) (5-day @
20 Deg. C)
Total Suspended Solids
pH
Ammonia
Bis(2-ethylhexyl) phthalate
Attachment F – Fact Sheet
1
lbs/day
2
lbs/day
3
lbs/day
4
lbs/day
mg/L
1
lbs/day
2
lbs/day
3
lbs/day
4
lbs/day
standard
units
mg/L
1
lbs/day
2
lbs/day
3
lbs/day
4
lbs/day
µg/L
Effluent Limitations
Maximum Instantaneous
Daily
Minimum
20
--
Average
Monthly
10
Average
Weekly
15
Instantaneous
Maximum
--
900
1000
1100
1300
10
900
1000
1100
1300
1400
1500
1700
2000
15
1400
1500
1700
2000
1800
2000
2300
2700
20
1800
2000
2300
2700
----------
----------
--
--
--
6.5
8.5
1.3
120
130
150
170
12
-------
2.1
190
200
240
280
49
-------
--------
F-78
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
Parameter
Copper
(total recoverable)
Chlorodibromomethane
Dichlorobromomethane
Methylmercury
Diazinon and Chlorpyrifos
Nitrate + Nitrite
(as N)
Chlorine, Total Residual
ORDER R5-2012-0115
NPDES NO. CA0079154
Effluent Limitations
Maximum Instantaneous
Daily
Minimum
Units
Average
Monthly
Average
Weekly
µg/L
15
--
10.4
--
--
µg/L
µg/L
grams
µg/L
8.0
11
5
0.77
-----
18
23
--
-----
-----
mg/L
10
--
--
10
11
--
-8
Instantaneous
Maximum
9
mg/L
-0.011
0.019
--MPN/
6
7
Total Coliform Organisms
-2.2
23
-240
100 mL
1
Based on an existing permitted flow of 10.8 mgd. Mass limits effective immediately and until compliance with
Special Provisions VI.C.6.a.
2
Based on a permitted flow of 12 mgd. Mass limits effective upon compliance with Special Provisions
VI.C.6.b.and until compliance with Special Provisions VI.C.6.c.
3
Based on a permitted flow of 13.6 mgd. Mass limits effective upon compliance with Special Provisions VI.C.6.c.
and until compliance with Special Provisions VI.C.6.d.
4
Based on a permitted flow of 16 mgd. Mass limits effective upon compliance with Special Provisions VI.C.6.d.
5
The total calendar annual load of methylmercury shall not exceed 0.77 grams.
6
Applied as a 7-day median effluent limitation.
7
Not to be exceeded more than once in any 30-day period.
8
Applied as a 4-day average effluent limitation.
9
Applied as a 1-hour average effluent limitation.
CDavg CC avg
10
S AMEL 

 1.0
0.079
0.012
CD-avg = average monthly diazinon effluent concentration in μg/L
CC-avg = average monthly chlorpyrifos effluent concentration in μg/L
C
C
11
SMDEL  Dmax  C max  1.0
0.16
0.025
5. Whole Effluent Toxicity (WET)
For compliance with the Basin Plan’s narrative toxicity objective, this Order
requires the Discharger to conduct whole effluent toxicity testing for acute and
chronic toxicity, as specified in the Monitoring and Reporting Program (Attachment
E section V.). This Order also contains effluent limitations for acute and chronic
toxicity and requires the Discharger to implement best management practices to
investigate the causes of, and identify corrective actions to reduce or eliminate
effluent toxicity.
a. Acute Aquatic Toxicity. The Basin Plan contains a narrative toxicity objective
that states, “All waters shall be maintained free of toxic substances in
concentrations that produce detrimental physiological responses in human,
plant, animal, or aquatic life.” (Basin Plan at page III-8.00 for discharges in the
Sac/SJ Basins). The Basin Plan also states that, “…effluent limits based upon
acute biotoxicity tests of effluents will be prescribed where appropriate…”.
Attachment F – Fact Sheet
F-79
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
For priority pollutants, the SIP dictates the procedures for conducting the RPA.
Acute toxicity is not a priority pollutant. Therefore, the Central Valley Water
Board is not restricted to one particular RPA method. Due to the site-specific
conditions of the discharge, the Central Valley Water Board has used its
judgment in determining the appropriate method for conducting the RPA for this
non-priority pollutant constituent. USEPA’s September 2010 NPDES Permit
Writer’s Manual, page 6-30, states, “State implementation procedures might
allow, or even require, a permit writer to determine reasonable potential through
a qualitative assessment process without using available facility-specific
effluent monitoring data or when such data are not available…A permitting
authority might also determine that WQBELs are required for specific pollutants
for all facilities that exhibit certain operational or discharge characteristics (e.g.,
WQBELs for pathogens in all permits for POTWs discharging to contact
recreational waters).” Although the discharge has been consistently in
compliance with the acute effluent limitations, the Facility is a POTW that treats
domestic wastewater containing ammonia and other acutely toxic pollutants.
Acute toxicity effluent limits are required to ensure compliance with the Basin
Plan’s narrative toxicity objective.
USEPA Region 9 provided guidance for the development of acute toxicity
effluent limitations in the absence of numeric water quality objectives for toxicity
in its document titled "Guidance for NPDES Permit Issuance", dated
February 1994. In section B.2. "Toxicity Requirements" (pgs. 14-15) it states
that, "In the absence of specific numeric water quality objectives for acute and
chronic toxicity, the narrative criterion 'no toxics in toxic amounts' applies.
Achievement of the narrative criterion, as applied herein, means that ambient
waters shall not demonstrate for acute toxicity: 1) less than 90% survival, 50%
of the time, based on the monthly median, or 2) less than 70% survival, 10% of
the time, based on any monthly median. Accordingly, effluent limitations for
acute toxicity have been included in this Order as follows:
Acute Toxicity. Survival of aquatic organisms in 96-hour bioassays of
undiluted waste shall be no less than:
Minimum for any one bioassay--------------------------------------- 70%
Median for any three consecutive bioassays --------------------- 90%
b. Chronic Aquatic Toxicity. Based on chronic WET testing performed by the
Discharger from February 2008 through November 2011, there was one
exceedance of the numeric monitoring trigger, as shown in Table F-13 below.
The Discharger conducted bi-weekly accelerated monitoring in accordance with
the permit and the results did not exceed the trigger. Therefore, a toxicity
reduction evaluation was not required. Based on the one exceedance of the
trigger, however, the discharge has reasonable potential to cause or contribute
to an in-stream excursion above of the Basin Plan’s narrative toxicity objective.
Attachment F – Fact Sheet
F-80
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Table F-13. Whole Effluent Chronic Toxicity Testing Results
Date
2/5/2008
5/6/2008
8/5/2008
9/9/2008
9/30/2008
10/7/2008
10/21/2008
11/4/2008
2/24/2009
5/5/2009
8/4/2009
11/3/2009
2/2/2010
5/11/2010
8/17/2010
11/16/2010
3/15/2011
5/10/2011
8/9/2011
11/15/2011
Fathead Minnow
Pimephales promelas
Survival
Growth
(TUc)
(TUc)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Water Flea
Green Algae
Ceriodaphnia dubia
Selenastrum capricornutum
Survival
Reproduction
Growth
(TUc)
(TUc)
(TUc)
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
The Monitoring and Reporting Program of this Order requires quarterly chronic
WET monitoring for demonstration of compliance with the narrative toxicity
objective. In addition to WET monitoring, the Special Provision in section
VI.C.2.a of the Order includes a numeric toxicity monitoring trigger,
requirements for accelerated monitoring, and requirements for TRE initiation if
toxicity is demonstrated.
Numeric chronic WET effluent limitations have not been included in this Order.
The SIP contains implementation gaps regarding the appropriate form and
implementation of chronic toxicity limits. This has resulted in the petitioning of a
NPDES permit in the Los Angeles Region24 that contained numeric chronic
toxicity effluent limitations. To address the petition, the State Water Board
adopted WQO 2003-012 directing its staff to revise the toxicity control
provisions in the SIP. The State Water Board states the following in WQO
2003-012, “In reviewing this petition and receiving comments from numerous
interested persons on the propriety of including numeric effluent limitations for
24
In the Matter of the Review of Own Motion of Waste Discharge Requirements Order Nos. R4-2002-0121
[NPDES No. CA0054011] and R4-2002-0123 [NPDES NO. CA0055119] and Time Schedule Order Nos.
R4-2002-0122 and R4-2002-0124 for Los Coyotes and Long Beach Wastewater Reclamation Plants Issued by
the California Regional Water Quality Control Board, Los Angeles Region SWRCB/OCC FILES A-1496 AND
1496(a)
Attachment F – Fact Sheet
F-81
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
chronic toxicity in NPDES permits for publicly-owned treatment works that
discharge to inland waters, we have determined that this issue should be
considered in a regulatory setting, in order to allow for full public discussion and
deliberation. We intend to modify the SIP to specifically address the issue. We
anticipate that review will occur within the next year. We therefore decline to
make a determination here regarding the propriety of the final numeric effluent
limitations for chronic toxicity contained in these permits.” The process to
revise the SIP is currently underway. Proposed changes include clarifying the
appropriate form of effluent toxicity limits in NPDES permits and general
expansion and standardization of toxicity control implementation related to the
NPDES permitting process. Since the toxicity control provisions in the SIP are
under revision it is infeasible to develop numeric effluent limitations for chronic
toxicity. Therefore, this Order includes a narrative effluent limitation and
requires that the Discharger meet best management practices for compliance
with the Basin Plan’s narrative toxicity objective, as allowed under
40 CFR 122.44(k).
To ensure compliance with the Basin Plan’s narrative toxicity objective, the
Discharger is required to conduct chronic WET testing, as specified in the
Monitoring and Reporting Program (Attachment E section V.). Furthermore, the
Special Provision contained at VI.C.2.a. of this Order requires the Discharger to
investigate the causes of, and identify and implement corrective actions to
reduce or eliminate effluent toxicity. If the discharge demonstrates toxicity
exceeding the numeric toxicity monitoring trigger, the Discharger is required to
initiate a Toxicity Reduction Evaluation (TRE) in accordance with an approved
TRE workplan. The numeric toxicity monitoring trigger is not an effluent
limitation; it is the toxicity threshold at which the Discharger is required to
perform accelerated chronic toxicity monitoring, as well as, the threshold to
initiate a TRE if effluent toxicity has been demonstrated.
D. Final Effluent Limitations
1. Mass-based Effluent Limitations
40 CFR 122.45(f)(1) requires effluent limitations be expressed in terms of mass,
with some exceptions, and 40 CFR 122.45(f)(2) allows pollutants that are limited in
terms of mass to additionally be limited in terms of other units of measurement.
This Order includes effluent limitations expressed in terms of mass and
concentration. In addition, pursuant to the exceptions to mass limitations provided
in 40 CFR 122.45(f)(1), some effluent limitations are not expressed in terms of
mass, such as pH and temperature, and when the applicable standards are
expressed in terms of concentration (e.g., CTR criteria and MCLs) and mass
limitations are not necessary to protect the beneficial uses of the receiving water.
Mass-based effluent limitations were calculated based upon the design flow
(Average Dry Weather Flow) permitted in section IV.A.1.a of this Order.
Attachment F – Fact Sheet
F-82
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
2.
ORDER R5-2012-0115
NPDES NO. CA0079154
Averaging Periods for Effluent Limitations
40 CFR 122.45 (d) requires average weekly and average monthly discharge
limitations for publicly owned treatment works (POTWs) unless impracticable.
However, for toxic pollutants and pollutant parameters in water quality permitting,
USEPA recommends the use of a maximum daily effluent limitation in lieu of
average weekly effluent limitations for two reasons. “First, the basis for the 7-day
average for POTWs derives from the secondary treatment requirements. This
basis is not related to the need for assuring achievement of water quality
standards. Second, a 7-day average, which could comprise up to seven or more
daily samples, could average out peak toxic concentrations and therefore the
discharge’s potential for causing acute toxic effects would be missed.” (TSD, pg.
96) This Order uses maximum daily effluent limitations in lieu of average weekly
effluent limitations for ammonia, bis(2-ethylhexyl)phthalate, copper,
chlorodibromomethane and dichlorobromomethane as recommended by the TSD
for the achievement of water quality standards and for the protection of the
beneficial uses of the receiving stream. Furthermore, for pH, total coliform
organisms, and total residual chlorine, weekly average effluent limitations have
been replaced or supplemented with effluent limitations utilizing shorter averaging
periods. The rationale for using shorter averaging periods for these constituents is
discussed in section IV.C.3 of this Fact Sheet.
3.
Satisfaction of Anti-Backsliding Requirements
The Clean Water Act specifies that a revised permit may not include effluent
limitations that are less stringent than the previous permit unless a less stringent
limitation is justified based on exceptions to the anti-backsliding provisions
contained in Clean Water Act sections 402(o) or 303(d)(4), or, where applicable,
40 CFR 122.44(l).
Based on the new information gathered over the term of Order R5-2007-0036-01,
the effluent limitations in this Order are at least as stringent as the effluent
limitations in the existing Order, with the exception of effluent limitations for
aluminum, chlorodibromomethane, dichlorobromomethane, dissolved oxygen, iron,
nitrate (as N) and nitrite (as N). The effluent limitations for these pollutants are
less stringent than those in Order R5-2007-0036-01. This relaxation of effluent
limitations is consistent with the anti-backsliding requirements of the CWA and
federal regulations.
a. Aluminum.
CWA section 402(o)(2). In the recent permit amendment due to the City’s
lawsuit, the Central Valley Water Board found that the USEPA NAWQC
chronic criterion (87 µg/L) was not applicable and applied the acute criterion
(750 µg/L) and the secondary MCL of 200 µg/L. The previous permit
includes an AMEL of 462 µg/L and MDEL of 755 µg/L for aluminum based
on the acute criterion, and a final annual average effluent limit of 200 µg/L.
The limits were included in the previous permit due to the receiving water
Attachment F – Fact Sheet
F-83
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
exceeding the USEPA acute criterion and the secondary MCL for aluminum.
Based on new tertiary effluent data for aluminum, the discharge does not
demonstrate reasonable potential, therefore, the effluent limits have been
removed in this Order. In accordance with section 402(o)(2) of the CWA the
effluent limits may be relaxed if, “There have been material and substantial
alterations or additions to the permitted facility which justify the application
of less stringent effluent limitations.” In this case, the Facility has been
upgraded to tertiary filtration since adoption of the last permit. The effluent
has demonstrated consistently low concentrations of aluminum since the
Facility upgrades, which results in a finding of no reasonable potential.
Therefore, the removal of these effluent limitations meet the exception to the
anti-backsliding requirements under CWA section 402(o)(2).
CWA section 402(o)(1) and 303(d)(4). CWA section 402(o)(1) specifies
that, in the case of effluent limitations established on the basis of CWA
section 301(b)(1)(C) (i.e., WQBELs), a permit may not be renewed,
reissued, or modified to contain effluent limitations which are less stringent
than the comparable effluent limitations in the previous permit except in
compliance with CWA section 303(d)(4). The effluent limitations for
aluminum established in previous Order R5-2007-0036-01 are WQBELs
and may be relaxed if the requirements of CWA section 303(d)(4) are
satisfied.
CWA section 303(d)(4) has two parts: paragraph (A) which applies to
nonattainment waters and paragraph (B) which applies to attainment
waters. For attainment waters, CWA section 303(d)(4)(B) specifies that a
limitation based on a water quality standard may be relaxed where the
action is consistent with the antidegradation policy. The 303(d) listings for
Old River and the Sacramento-San Joaquin Delta, as described in section
III.D.1 of this Fact Sheet, do not include aluminum. Thus, the receiving
water is an attainment water for aluminum25. As discussed in section IV.D.4,
the removal of WQBELs for aluminum is consistent with the antidegradation
provisions of 40 CFR 131.12 and State Water Board Resolution No. 68-16.
Therefore, the removal of these effluent limitations meet the exception to the
anti-backsliding requirements under CWA section 402(o)(1) and 303(d)(4).
b. Chlorodibromomethane (CDBM) and Dichlorobromomethane (DCBM).
The water quality-based effluent limits (WQBELs) for CDBM and DCBM in
this Order are less stringent than in previous Order R5-2007-0036-01. The
WQBELs are less stringent because new background receiving water data
for CDBM and DCBM was made available for the WQBEL calculations that
were not available at the time the WQBELs in the previous permit were
established.
25
The exceptions in Section 303(d)(4) address both waters in attainment with water quality standards and those
not in attainment, i.e. waters on the section 303(d) impaired waters list.” See In the Matter of the Petition of the
Environmental Law Foundation, WQO 2008-0006 at p. 4.
Attachment F – Fact Sheet
F-84
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
During the term of the previous permit, the Discharger collected new data
for the background receiving water using improved analytical methods with
a lower method detection limit. Similar to the previous permit, all data was
below detection limits. The use of lower method detection limits
demonstrated there is more assimilative capacity for CDBM and DCBM in
the receiving water than previously determined. Dilution credits are allowed
for CDBM and DCBM, so the available assimilative capacity impacts the
WQBEL calculations. In accordance with Section 1.4.3.2 of the SIP, when
dilution credits are used for the WQBEL calculations and all background
receiving water data is non-detect, the lowest method detection limit is used
to represent the maximum ambient background concentration.
Consequently, the new data using lower method detection limits results in
less stringent WQBELs.
In the previous Order, the Central Valley Water Board authorized dilution
credits for CDBM and DCBM and found the utilization of some assimilative
capacity for these constituents complied with the antidegradation provisions
of 40 CFR 131.12 and State Water Board Resolution 68-16. In Table F-11
below, it is demonstrated that although the effluent limits have increased in
this Order, the estimated amount of assimilative capacity used has not
increased due to the new information. To evaluate the use of assimilative
capacity, the estimated receiving water concentrations at the Clifton Court
Forebay (a representative far-field location) were estimated using the Delta
Simulation Model 2 (DSM2) modeling discussed in Section IV.C.2.c.vi of the
Fact Sheet. Table F-14 shows the estimated mixed receiving water
concentrations of CDBM and DCBM at Clifton Court Forebay for the
previous permit and this permit. As demonstrated below, although the
effluent limits are increased in this permit, the estimated impacts on the
receiving water at the far-field location are reduced from the previously
estimated impacts determined in the previous Order. Therefore, the
estimated degradation is reduced and the increased effluent limits are
consistent with the antidegradation provisions of 40 CFR 131.12 and State
Water Board Resolution 68-16. Compliance with these WQBELs will result
in the use of best practicable treatment or control of the discharge and the
impact on existing water quality will be insignificant.
Table F-14. Determination of Assimilative Capacity for CDBM and DCBM
Far-Field Location
Clifton Court Forebay
Estimated Background
Concentration
Constituent
CDBM
DCBM
CTR
Criterion
0.41 µg/L
0.56 µg/L
Attachment F – Fact Sheet
Previous
Permit
<0.25 µg/L
<0.25 µg/L
Current
Permit
<0.03 µg/L
<0.06 µg/L
Average Monthly
Effluent Limit
Previous
Permit
3.6 µg/L
6.8 µg/L
Current
Permit
8 µg/L
11 µg/L
Mixed Receiving
Water Concentration
Effluent
Fraction
2%
2%
Previous
Permit
0.32 µg/L
0.39 µg/L
Current
Permit
0.19 µg/L
0.28 µg/L
F-85
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Section 303(d)(4)(B) of the Clean Water Act (CWA) for attainment waters,
provides that WQBELs based on a total maximum daily load (TMDL), waste
load allocation (WLA), other water quality standard, or any other permitting
standard may be relaxed where the action is consistent with state’s
antidegradation policy. The action to relax the WQBELs for CDBM and
DCBM complies with State Water Board Resolution 68-16, which meets the
exception to backsliding in accordance with section 303(d)(4)(B) of the
CWA.
c. Iron.
CWA section 402(o)(2). Previous Order R5-2007-0036-01 included an
effluent limit for total recoverable iron of of 300 mg/L for the discharge,
applied as an annual average. Based on tertiary effluent data for iron, the
discharge does not demonstrate reasonable potential, therefore, the effluent
limit has been removed in this Order. In accordance with section 402(o)(2)
of the CWA the effluent limits may be relaxed if, “There have been material
and substantial alterations or additions to the permitted facility which justify
the application of less stringent effluent limitations.” In this case, the Facility
has been upgraded to tertiary filtration since adoption of the last permit.
The effluent has demonstrated consistently low concentrations of iron since
the Facility upgrades, which results in a finding of no reasonable potential.
Therefore, the removal of these effluent limitations meet the exception to the
anti-backsliding requirements under CWA section 402(o)(2).
CWA section 402(o)(1) and 303(d)(4). CWA section 402(o)(1) specifies
that, in the case of effluent limitations established on the basis of CWA
section 301(b)(1)(C) (i.e., WQBELs), a permit may not be renewed,
reissued, or modified to contain effluent limitations which are less stringent
than the comparable effluent limitations in the previous permit except in
compliance with CWA section 303(d)(4). The effluent limitations for iron
established in previous Order R5-2007-0036-01 are WQBELs and may be
relaxed if the requirements of CWA section 303(d)(4) are satisfied.
CWA section 303(d)(4) has two parts: paragraph (A) which applies to
nonattainment waters and paragraph (B) which applies to attainment
waters. For attainment waters, CWA section 303(d)(4)(B) specifies that a
limitation based on a water quality standard may be relaxed where the
action is consistent with the antidegradation policy. The 303(d) listings for
Old River and the Sacramento-San Joaquin Delta, as described in section
III.D.1 of this Fact Sheet, do not include iron. Thus, the receiving water is an
attainment water for iron26. As discussed in section IV.D.4, the removal of
WQBELs for iron is consistent with the antidegradation provisions of 40
CFR 131.12 and State Water Board Resolution No. 68-16. Therefore, the
26
“The exceptions in Section 303(d)(4) address both waters in attainment with water quality standards and those
not in attainment, i.e. waters on the section 303(d) impaired waters list.” See In the Matter of the Petition of the
Environmental Law Foundation, WQO 2008-0006 at p. 4.
Attachment F – Fact Sheet
F-86
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
removal of these effluent limitations meet the exception to the antibacksliding requirements under CWA section 402(o)(1) and 303(d)(4).
d. Dissolved Oxygen. Previous Order R5-2007-0036-01 included an effluent
limit for dissolved oxygen of 5 mg/L as a daily average. Based on data
collected since the adoption of the previous Order, the discharge does not
demonstrate reasonable potential to cause or contribute to an exceedance
of the applicable water quality objectives for dissolved oxygen in the
receiving water. Therefore, the dissolved oxygen effluent limit has been
removed in this Order. In accordance with section 402(o)(2) of the CWA the
effluent limits may be relaxed if, “There have been material and substantial
alterations or additions to the permitted facility which justify the application
of less stringent effluent limitations.” In this case, the Facility has been
upgraded to tertiary filtration since adoption of the last permit that has
resulted in a significant reduction in oxygen-demanding substances (e.g.,
biochemical oxygen demand, ammonia, and total suspended solids).
4.
Satisfaction of Antidegradation Policy
This Order does not allow for an increase in flow or mass of pollutants to the
receiving water. Therefore, a complete antidegradation analysis is not necessary.
The Order requires compliance with applicable federal technology-based
standards and with WQBELs where the discharge could have the reasonable
potential to cause or contribute to an exceedance of water quality standards. The
permitted discharge is consistent with the antidegradation provisions of
40 CFR 131.12 and State Water Board Resolution No. 68-16. Compliance with
these requirements will result in the use of best practicable treatment or control of
the discharge. The impact on existing water quality will be insignificant.
This Order removes existing effluent limitations for constituents in which updated
monitoring data demonstrates that the effluent does not cause or contribute to an
exceedance of the applicable water quality criteria or objectives in the receiving
water. The Central Valley Water Board finds that the removal of the effluent
limitations does not result in an allowed increase in pollutants or any additional
degradation of the receiving water. Thus, the removal of effluent limitations is
consistent with the antidegradation provisions of 40 CFR 131.12 and State Water
Board Resolution No. 68-16.
The permitted surface water discharge is consistent with the antidegradation
provisions of 40 CFR 131.12 and State Water Board Resolution No. 68-16.
Compliance with these requirements will result in the use of best practicable
treatment or control of the discharge. The impact on existing water quality will be
insignificant.
5.
Stringency of Requirements for Individual Pollutants
This Order contains both technology-based effluent limitations and WQBELs for
individual pollutants. The technology-based effluent limitations consist of
Attachment F – Fact Sheet
F-87
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
restrictions on Flow. The WQBELs consist of restrictions on ammonia, bis(2ethylhexyl)phthalate, chlorodibromomethane, copper, BOD, TSS, pH, total coliform
organisms, total residual chlorine, and dichlorobromomethane. This Order’s
technology-based pollutant restrictions implement the minimum, applicable federal
technology-based requirements. In addition, this Order includes new effluent
limitations for nitrate + nitrite (as N) to meet numeric objectives or protect beneficial
uses.
This Order does not contain pollutant restrictions that are more stringent than
applicable federal requirements and standards.
Summary of Final Effluent Limitations
Discharge Point No. 001 and Discharge Point No. 002
Table F-15. Summary of Final Effluent Limitations
Parameter
Flow
Biochemical Oxygen
Demand
Total Suspended Solids
pH
Ammonia (as N)
Bis(2ethylhexyl)Phthalate
Chlorine, Total
Residual
Chlorodibromomethane
Attachment F – Fact Sheet
Units
MGD
MGD
MGD
MGD
mg/L
lbs/day
lbs/day
lbs/day
lbs/day
%
Removal
mg/L
lbs/day
lbs/day
lbs/day
Average
Monthly
-----
Average
Weekly
-----
10
900
1001
1134
1334
15
1351
1501
1701
2002
85
--
10
900
1001
1134
1334
15
1351
1501
1701
2002
85
--
--
Effluent Limitations
Maximum
Instantaneous
Daily
Minimum
-10.8
-12
-13.6
-16
-20
-1801
-2002
-2268
-2669
---
Instantaneous
Maximum
-----------
Basis
1
PF
TTC
CFR
20
1801
2002
2268
2669
--
-------
-------
--
--
6.5
8.5
BP, PB
------
2.1
189
210
238
280
------
------
NAWQC
lbs/day
1.3
117
130
147
173
μg/L
12
--
79
--
--
CTR
mg/L
--
0.011
0.019
--
--
NAWQC
μg/L
8.0
--
18
--
--
CTR
lbs/day
%
Removal
standard
units
mg/L
lbs/day
lbs/day
lbs/day
2
3
TTC
CFR
F-88
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Effluent Limitations
Maximum
Instantaneous
Daily
Minimum
Units
Average
Monthly
Average
Weekly
Copper, Total
Recoverable
Diazinon and
Chlorpyrifos
Dichlorobromomethane
Dissolved Oxygen
μg/L
15
--
10.4
--
--
CTR,
BP
µg/L
4
--
5
--
--
BP
μg/L
mg/L
11
--
---
23
9
5
---
---
CTR
BP
Methylmercury
grams
0.77
--
--
--
--
BP
mg/L
10
--
--
--
--
MCL
MPN/100
mL
--
2.2
--
240
Title 22
Nitrite Plus Nitrate
(as N)
Total Coliform
Organisms
1
2
3
4
5
6
7
8
9
8
6
7
23
Instantaneous
Maximum
Basis
1
Parameter
PF – Based on permitted flow of the Facility ranging from 10.8 MGD to 16 MGD to coincide with phased upgrade
project.
TTC – Based on tertiary treatment capability. These effluent limitations reflect the capability of a properly operated
tertiary treatment plant.
CFR – Based on secondary treatment standards contained in 40 CFR Part 133.
BP – Based on water quality objectives contained in the Basin Plan.
CTR – Based on water quality criteria contained in the California Toxics Rule and applied as specified in the SIP.
NAWQC – Based on USEPA’s National Ambient Water Quality Criteria for the protection of freshwater aquatic life.
SEC MCL – Based on the Secondary Maximum Contaminant Level.
TMDL – Based on the TMDL for salinity and boron in the lower San Joaquin River.
MCL – Based on the Primary Maximum Contaminant Level.
Title 22 – Based on CA Department of Public Health Reclamation Criteria, CCR, Division 4, Chapter 3 (Title 22).
Applied as a 4-day average effluent limitation.
Applied as a 1-hour average effluent limitation.
CDavg CC avg
S AMEL 

 1.0
0.079
0.012
CD-avg = average monthly diazinon effluent concentration in μg/L
CC-avg = average monthly chlorpyrifos effluent concentration in μg/L
C
C
SMDEL  Dmax  C max  1.0
0.16
0.025
CD-max = maximum daily diazinon effluent concentration in μg/L
CC-max = maximum daily chlorpyrifos effluent concentration in μg/L
Applied as a 7-day median effluent limitation.
Not to be exceeded more than once in any 30-day period.
The total calendar annual load of methylmercury shall not exceed 0.77 grams.
Average daily dissolved oxygen shall not be less than 5 mg/L.
E. Interim Effluent Limitations
1. Compliance Schedule for Mercury. The permit limitations for methylmercury are
more stringent than the limitations previously imposed. These new limitations are
based on the Basin Plan’s Delta Mercury Control Program that became effective
on 20 October 2011. The Discharger has complied with the application
requirements in paragraph 4 of the State Water Board’s Compliance Schedule
Policy, and the Discharger’s application demonstrates the need for additional time
Attachment F – Fact Sheet
F-89
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
to implement actions to comply with the new limitations, as described below.
Therefore, a compliance schedule for compliance with the effluent limitations for
methylmercury is established in this Order.
A compliance schedule is necessary because the Discharger must implement
actions, including a Phase 1 Methylmercury Control Study and possible facility
upgrades to comply with the final effluent limitations.
The Discharger has made diligent efforts to quantify pollutant levels in the
discharge and the sources of the pollutant in the waste stream, and the results of
those efforts. The Discharger is currently implementing a pollution prevention plan
for mercury that was submitted to the Central Valley Water Board on 21 June
2012.
The compliance schedule is as short as possible. The Central Valley Water Board
will use the Phase 1 Control Studies’ results and other information to consider
amendments to the Delta Mercury Control Program during the Phase 1 Delta
Mercury Control Program Review. Therefore, at this time it is uncertain what
measures must be taken to consistently comply with the waste load allocation for
methylmercury. The interim effluent limits and final compliance date may be
modified at the completion of Phase 1.
Interim performance-based limitations have been established in this Order in
accordance with the Delta Mercury Control Program. The interim limitations were
determined as described in section IV.E.2., below, and are in effect through until
the final limitations take effect.
2. Interim Limits for Total Mercury. During Phase 1, the Delta Mercury Control
Program requires POTWs to limit their discharges of inorganic (total) mercury to
facility performance-based levels. The interim inorganic (total) mercury effluent
mass limit is to be derived using current, representative data and shall not exceed
the 99.9th percentile of 12-month running effluent inorganic (total) mercury loads
(lbs/year). At the end of Phase 1, the interim inorganic (total) mercury mass limit
will be re-evaluated and modified as appropriate.
The interim limitations for total mercury in this Order are based on the current
treatment plant performance. In developing the interim limitation, where there are
10 sampling data points or more, sampling and laboratory variability is accounted
for by establishing interim limits that are based on normally distributed data where
99.9% of the data points will lie within 3.3 standard deviations of the mean (Basic
Statistical Methods for Engineers and Scientists, Kennedy and Neville, Harper and
Row). Therefore, the 99.9th percentile was determined using the mean plus 3.3
standard deviations of the available data.
Total mercury effluent data collected since the operation of tertiary filtration, from
August 2008 through December 2011, was used in the determination of the
performance-based interim effluent limits. 12-month running mercury loads were
Attachment F – Fact Sheet
F-90
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
calculated, the average and standard deviation of the 12-month running mercury
loads were determined, and used to calculate the 99.9th percentile.
The Central Valley Water Board finds that the Discharger can undertake source
control and treatment plant measures to maintain compliance with the interim
limitations included in this Order. Interim limitations are established when
compliance with final effluent limitations cannot be achieved by the existing
discharge. Discharge of constituents in concentrations in excess of the final
effluent limitations, but in compliance with the interim effluent limitations, can
significantly degrade water quality and adversely affect the beneficial uses of the
receiving stream on a long-term basis. The interim limitations, however, establish
an enforceable ceiling concentration until compliance with the effluent limitation
can be achieved.
The following table summarizes the calculations of the interim effluent limitations
for total mercury:
Table F-16. Interim Effluent Limitation Calculation Summary
Parameter
Total
Mercury
Units
Maximum Annual
Effluent Loading
Mean
Standard
Deviation
Number of
Samples
Interim
Limitation
g/yr
40.4
27.3
4.02
45
41
F. Land Discharge Specifications (see Order R5-2007-0038)
G. Reclamation Specifications (Not Applicable)
V.
RATIONALE FOR RECEIVING WATER LIMITATIONS
Basin Plan water quality objectives to protect the beneficial uses of surface water and
groundwater include numeric objectives and narrative objectives, including objectives for
chemical constituents, toxicity, and tastes and odors. The toxicity objective requires that
surface water and groundwater be maintained free of toxic substances in concentrations
that produce detrimental physiological responses in humans, plants, animals, or aquatic
life. The chemical constituent objective requires that surface water and groundwater shall
not contain chemical constituents in concentrations that adversely affect any beneficial
use or that exceed the maximum contaminant levels (MCLs) in Title 22, CCR. The tastes
and odors objective states that surface water and groundwater shall not contain taste- or
odor-producing substances in concentrations that cause nuisance or adversely affect
beneficial uses. The Basin Plan requires the application of the most stringent objective
necessary to ensure that surface water and groundwater do not contain chemical
constituents, toxic substances, radionuclides, or taste and odor producing substances in
concentrations that adversely affect domestic drinking water supply, agricultural supply, or
any other beneficial use.
Attachment F – Fact Sheet
F-91
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
A. Surface Water
1.
CWA section 303(a-c), requires states to adopt water quality standards, including
criteria where they are necessary to protect beneficial uses. The Central Valley
Water Board adopted water quality criteria as water quality objectives in the Basin
Plan. The Basin Plan states that “[t]he numerical and narrative water quality
objectives define the least stringent standards that the Regional Water Board will
apply to regional waters in order to protect the beneficial uses.” The Basin Plan
includes numeric and narrative water quality objectives for various beneficial uses
and water bodies. This Order contains receiving surface water limitations based
on the Basin Plan numerical and narrative water quality objectives for bacteria,
biostimulatory substances, color, chemical constituents, dissolved oxygen, floating
material, oil and grease, pH, pesticides, radioactivity, salinity, suspended sediment,
settleable substances, suspended material, tastes and odors, temperature, toxicity,
and turbidity. The following receiving water limitations were removed from the
existing Order R5-2007-36-01. Removal of these limitations will continue to be
protective of beneficial uses, consistent with the maximum benefit to people of the
State, which is consistent with antidegradation policies.
a. Aquatic communities and populations, including vertebrate, invertebrate, and
plant species, to be degraded.
b. Esthetically undesirable discoloration.
c. Fungi, slimes, or other objectionable growths.
B. Groundwater. (Set forth in Order R5-2007-0038)
VI.
RATIONALE FOR MONITORING AND REPORTING REQUIREMENTS
40 CFR 122.48 requires that all NPDES permits specify requirements for recording and
reporting monitoring results. Water Code sections 13267 and 13383 authorize the
Regional Water Boards to require technical and monitoring reports. The Monitoring and
Reporting Program (Attachment E) of this Order, establishes monitoring and reporting
requirements to implement federal and state requirements. The following provides the
rationale for the monitoring and reporting requirements contained in the Monitoring and
Reporting Program for the Facility.
A. Influent Monitoring
1. Domestic influent monitoring for the main treatment facility and industrial influent
monitoring for the industrial treatment facility is required in this Order. Influent
monitoring is required to collect data on the characteristics of the wastewater and
to assess compliance with effluent limitations (e.g., BOD5 and TSS reduction
requirements). The monitoring frequencies for flow (continuous), pH (continuous),
BOD5 (daily), TSS (daily), TDS (weekly), and EC (weekly) have been retained from
Order R5-2007-0036-01. Domestic influent monthly monitoring requirements for
methylmercury have not been retained from Order R5-2007-0036-01 as they are
Attachment F – Fact Sheet
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
not necessary to determine compliance with permit requirements. Methylmercury
will be performed as part of the Methylmercury Control Studies required under
Phase I of the Delta Mercury TMDL, separate from the NPDES permit.
B. Effluent Monitoring
1. Pursuant to the requirements of 40 CFR 122.44(i)(2) effluent monitoring is required
for all constituents with effluent limitations. Effluent monitoring is necessary to
assess compliance with effluent limitations, assess the effectiveness of the
treatment process, and to assess the impacts of the discharge on the receiving
stream and groundwater.
2. Effluent monitoring frequencies and sample types for flow (continuous), total
residual chlorine (continuous), temperature (continuous), pH (continuous), BOD 5
(daily), TSS (daily), total coliform organisms (daily), settleable solids (monthly),
dissolved oxygen (continuous), ammonia (weekly), nitrate (weekly), nitrite (weekly),
total phosphorus (monthly), total kjeldahl nitrogen (monthly), total organic carbon
(monthly), EC (weekly), TDS (monthly), dichlorobromomethane (monthly),
chlorodibromomethane (monthly), mercury (monthly) and bis(2ethylhexyl)phthalate (monthly) have been retained from Order R5-2007-0036-01to
determine compliance with effluent limitations or the Facility’s impact on the
beneficial uses of the receiving water.
3. Monthly effluent monitoring for hardness (as CaCO3) has been included in this
Order to evaluate compliance with CTR hardness dependent metals.
4. This Order retains effluent limitations for copper from Order R5-2007-0036-01.
Monitoring data over the term of Order R5-2007-0036-01 indicates reasonable
potential to cause or contribute to an exceedance of water quality criteria based on
the background concentration of the receiving water exceeding the CTR criteria.
However, effluent monitoring data does not exceed either the BP objective or the
CTR criteria. Therefore, this Order reduces the monitoring frequency for copper
from monthly to quarterly.
5. Monthly effluent monitoring data collected over the existing permit term for
aluminum, iron, and manganese) did not demonstrate reasonable potential to
exceed water quality objectives/criteria. Thus, specific monitoring requirements for
these parameters will only be required as part of the Effluent and Receiving Water
Characterization Study (monitoring every other month during 3 rd or 4th year of this
Order). See the Monitoring and Reporting Program (Attachment E) of this Order.
6. Monthly effluent monitoring data collected over the existing permit term for oil and
grease, bromoform, and chloroform did not demonstrate reasonable potential to
exceed water quality objectives/criteria. Thus, specific monitoring requirements for
these parameters have not been retained from Order R5-2007-0036-01.
7. Chlorpyrifos and Diazinon. This Order requires that pollutants be analyzed using
the analytical methods described in 40 CFR Part 136 or an EPA approved
Attachment F – Fact Sheet
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Alternate Testing Procedure. However, where no methods are specified for a
given pollutant that meets a specific reporting limit or method performance
standard, an alternate method can be approved by the Central Valley Water Board.
This Order requires either EPA 8141A or EPA 625M for chlorpyrifos and diazinon.
These alternate analytical methods are necessary to determine compliance with
the effluent limits for these constituents. Basin Plan water quality objectives for
chlorpyrifos and diazinon are 0.015 µg/L and 0.1 µg/L, respectively (as a 4-day
average. See Attachment F, Section IV.C.3.b.i.(a) for more information).
Therefore, chlorpyrifos and diazinon must be analyzed using analytical methods
that have a lower MDL than the Basin Plan water quality objectives.
8. California Water Code section 13176, subdivision (a), states: “The analysis of any
material required by [Water Code sections 13000-16104] shall be performed by a
laboratory that has accreditation or certification pursuant to Article 3 (commencing
with Section 100825) of Chapter 4 of Part 1 of Division 101 of the Health and
Safety Code.” The Department of Public Health certifies laboratories through its
Environmental Laboratory Accreditation Program (ELAP).
Section 13176 cannot be interpreted in a manner that would violate federal holding
time requirements that apply to NPDES permits pursuant to the Clean Water Act.
(Wat. Code §§ 13370, subd. (c), 13372, 13377.) Section 13176 is inapplicable to
NPDES permits to the extent it is inconsistent with Clean Water Act requirements.
(Wat. Code § 13372, subd. (a).) The holding time requirements are 15 minutes for
chlorine residual, dissolved oxygen, and pH, and immediate analysis is required for
temperature. (40 C.F.R. § 136.3(e), Table II)
C. Whole Effluent Toxicity Testing Requirements
1. Acute Toxicity. 96-hour bioassay testing is required to demonstrate compliance
with the effluent limitation for acute toxicity. Previous Order R5-2007-0036-01
required weekly 96-hour acute bioassays. Since upgrading to tertiary treatment,
the Discharger has demonstrated consistent compliance with the acute toxicity
effluent limits. Therefore, the monitoring frequency for the 96-hour acute
bioassays has been reduced to monthly in this Order.
Acute toxicity testing shall be conducted in accordance with USEPA’s Methods for
Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and
Marine Organisms, October 2002 (EPA-821-R-02-012, Fifth Edition ). EPA’s acute
toxicity testing method allows the use of either the test species Pimephales
promelas (fathead minnow) or Oncorhynchus mykiss (rainbow trout). Due to the
presence of salmon and steelhead in Old River, this Order requires the use of
Oncorhynchus mykiss (rainbow trout) as the test species.
2. Chronic Toxicity. Quarterly chronic whole effluent toxicity testing is required in
order to demonstrate compliance with the Basin Plan’s narrative toxicity objective.
This is consistent with previous Order R5-2007-0036-01
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
D. Receiving Water Monitoring
1. Surface Water
Receiving water monitoring is necessary to assess compliance with receiving
water limitations and to assess the impacts of the discharge on the receiving
stream.
2. Groundwater. (Set forth in Order R5-2007-0038)
E. Other Monitoring Requirements
1. Biosolids Monitoring. (Set forth in Order R5-2007-0038)
Biosolids monitoring is required to ensure compliance with the biosolids disposal
requirements contained in the Special Provision contained in section VI.C.6.a. of
this Order. Biosolids disposal requirements are imposed pursuant to
40 CFR Part 503 to protect public health and prevent groundwater degradation.
2. Water Supply Monitoring
Water supply monitoring is required to evaluate the source of constituents in the
wastewater.
3. Effluent and Receiving Water Characterization Study.
An effluent and receiving water monitoring study is required to ensure adequate
information is available for the next permit renewal. During the third or fourth year
of this permit term, the Discharger is required to conduct monthly monitoring of the
effluent at EFF-001 and of the receiving water at RSW-001 for all priority pollutants
and other constituents of concern as described in Attachment I. During the term of
this Order, Dioxin and furan sampling shall be performed for three consecutive
years during dry weather, as described in Attachment J.
VII. RATIONALE FOR PROVISIONS
A. Standard Provisions
Standard Provisions, which apply to all NPDES permits in accordance with
40 CFR 122.41, and additional conditions applicable to specified categories of permits
in accordance with 40 CFR 122.42, are provided in Attachment D. The discharger
must comply with all standard provisions and with those additional conditions that are
applicable under 40 CFR 122.42.
40 CFR 122.41(a)(1) and (b) through (n) establish conditions that apply to all Stateissued NPDES permits. These conditions must be incorporated into the permits either
expressly or by reference. If incorporated by reference, a specific citation to the
regulations must be included in the Order. 40 CFR 123.25(a)(12) allows the state to
omit or modify conditions to impose more stringent requirements. In accordance with
Attachment F – Fact Sheet
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
40 CFR 123.25, this Order omits federal conditions that address enforcement authority
specified in 40 CFR 122.41(j)(5) and (k)(2) because the enforcement authority under
the Water Code is more stringent. In lieu of these conditions, this Order incorporates
by reference Water Code section 13387(e).
B. Special Provisions
1. Reopener Provisions
a. Mercury. The Delta Mercury Control Program was designed to proceed in two
phases. Phase 1 spans a period of approximately nine years. Phase 1
emphasizes studies and pilot projects to develop and evaluate management
practices to control methylmercury. At the end of Phase 1, the Central Valley
Water Board will conduct a Phase 1 Delta Mercury Control Program Review
that considers: modification of methylmercury goals, objectives, allocations
and/or the Final Compliance Date; implementation of management practices
and schedules for methylmercury controls; and adoption of a mercury offset
program for dischargers who cannot meet their load and waste load allocations
after implementing all reasonable load reduction strategies. The fish tissue
objectives, the linkage analysis between objectives and sources, and the
attainability of the allocations will be re-evaluated based on the findings of
Phase 1 control studies and other information. The linkage analysis, fish tissue
objectives, allocations, and time schedules may be adjusted at the end of
Phase 1, or subsequent program reviews, as appropriate. Therefore, this
Order may be reopened to address changes to the Delta Mercury Control
Program.
b. Pollution Prevention. This Order requires the Discharger prepare pollution
prevention plans following Water Code section 13263.3(d)(3) for salinity. This
reopener provision allows the Central Valley Water Board to reopen this Order
for addition and/or modification of effluent limitations and requirements for
these constituents based on a review of the pollution prevention plans.
c. Whole Effluent Toxicity. This Order requires the Discharger to investigate the
causes of, and identify corrective actions to reduce or eliminate effluent toxicity
through a Toxicity Reduction Evaluation (TRE). This Order may be reopened
to include a numeric chronic toxicity limitation, a new acute toxicity limitation,
and/or a limitation for a specific toxicant identified in the TRE. Additionally, if
the State Water Board revises the SIP’s toxicity control provisions, this Order
may be reopened to be consistent with the new provisions.
d. Water Effects Ratio (WER) and Metal Translators. A default WER of 1.0 has
been used in this Order for calculating CTR criteria for applicable priority
pollutant inorganic constituents. In addition, default dissolved-to-total metal
translators have been used to convert water quality objectives from dissolved to
total recoverable when developing effluent limitations for non-priority pollutant
metals. If the Discharger performs studies to determine site-specific WERs
and/or site-specific dissolved-to-total metal translators, this Order may be
Attachment F – Fact Sheet
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
reopened to modify the effluent limitations for the applicable inorganic
constituents.
e. Bay-Delta Plan South Salinity Objectives Update. The State Water Board is
currently in the process of updating the South Delta Salinity Objectives
contained in the Bay-Delta Plan. The updated salinity objectives may result in
needed changes to the salinity requirements in this Order. Therefore, this
Order may be reopened to modify salinity requirements, as appropriate, in
accordance with changes to the Bay-Delta Plan.
2. Special Studies and Additional Monitoring Requirements
a. Chronic Whole Effluent Toxicity Requirements. The Basin Plan contains a
narrative toxicity objective that states, “All waters shall be maintained free of
toxic substances in concentrations that produce detrimental physiological
responses in human, plant, animal, or aquatic life.” (Basin Plan at page III-8.00)
Based on whole effluent chronic toxicity testing performed by the Discharger
from February 2008 through November 2011, the discharge has reasonable
potential to cause or contribute to an in-stream excursion above of the Basin
Plan’s narrative toxicity objective. Use the following paragraph and delete the
one below it if the discharge exhibits reasonable potential.
This provision requires the Discharger to develop a TRE Workplan in
accordance with USEPA guidance. In addition, the provision provides a
numeric toxicity monitoring trigger and requirements for accelerated monitoring,
as well as, requirements for TRE initiation if toxicity has been demonstrated.
Monitoring Trigger. A numeric toxicity monitoring trigger of > 1 TUc (where
TUc = 100/NOEC) is applied in the provision, because this Order does not
allow any dilution for the chronic condition. Therefore, a TRE is triggered when
the effluent exhibits toxicity at 100% effluent.
Accelerated Monitoring. The provision requires accelerated WET testing
when a regular WET test result exceeds the monitoring trigger. The purpose of
accelerated monitoring is to determine, in an expedient manner, whether there
is toxicity before requiring the implementation of a TRE. Due to possible
seasonality of the toxicity, the accelerated monitoring should be performed in a
timely manner, preferably taking no more than 2 to 3 months to complete.
The provision requires accelerated monitoring consisting of four chronic toxicity
tests in a six-week period (i.e., one test every two weeks) using the species that
exhibited toxicity. Guidance regarding accelerated monitoring and TRE
initiation is provided in the Technical Support Document for Water Qualitybased Toxics Control, EPA/505/2-90-001, March 1991 (TSD). The TSD at
page 118 states, “EPA recommends if toxicity is repeatedly or periodically
present at levels above effluent limits more than 20 percent of the time, a TRE
should be required.” Therefore, four accelerated monitoring tests are required
in this provision. If no toxicity is demonstrated in the four accelerated tests,
Attachment F – Fact Sheet
F-97
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
then it demonstrates that toxicity is not present at levels above the monitoring
trigger more than 20 percent of the time (only 1 of 5 tests are toxic, including
the initial test). However, notwithstanding the accelerated monitoring results, if
there is adequate evidence of effluent toxicity (i.e. toxicity present exceeding
the monitoring trigger more than 20 percent of the time), the Executive Officer
may require that the Discharger initiate a TRE.
See the WET Accelerated Monitoring Flow Chart (Figure F-2), below, for further
clarification of the accelerated monitoring requirements and for the decision
points for determining the need for TRE initiation.
TRE Workplan. The Discharger submitted a TRE Workplan that was
determined to be sufficient and was approved by the Executive Officer.
Attachment F – Fact Sheet
F-98
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Figure F-2
WET Accelerated Monitoring Flow Chart
Regular Effluent
Toxicity Monitoring
Re-sample and re-test as
soon as possible, not to
exceed 14-days from
notification of test failure
No
Test Acceptability
Criteria (TAC)
Met?
Yes
Monitoring
Trigger
Exceeded?
No
Yes
Initiate Accelerated Monitoring
using the toxicity testing
species that exhibited toxicity
Make facility corrections and
complete accelerated
monitoring to confirm removal
of effluent toxicity
Yes
Effluent toxicity
easily identified
(e.g., plant upset)
No
Cease accelerated monitoring
and resume regular chronic
toxicity monitoring
No
Monitoring
Trigger exceeded
during accelerated
monitoring
Yes
Implement
Toxicity Reduction
Evaluation
Attachment F – Fact Sheet
F-99
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
b. Phase 1 Methylmercury Control Study. The Basin Plan’s Delta Mercury
Control Program requires NPDES dischargers, working with other stakeholders,
to conduct methylmercury control studies (Control Studies) to evaluate existing
control methods and, as needed, develop additional control methods that could
be implemented to achieve their methylmercury load and waste load
allocations. Control Studies can be developed through a stakeholder group
approach or other collaborative mechanism, or by individual dischargers. By
letter dated 16 April 2012, the Discharger agreed to participate in the Central
Valley Clean Water Association (CVCWA) Coordinated Methylmercury Control
Study (Study).
The Central Valley Water Board will use the Phase 1 Control Studies’ results
and other information to consider amendments to the Delta Mercury Control
Program during the Phase 1 Delta Mercury Control Program Review. The
objective of the Control Studies is to evaluate existing control methods and, as
needed, develop additional control methods that could be implemented to
achieve the methylmercury load and waste load allocation. In accordance with
the Delta Mercury Control Plan, a work plan shall be submitted by
20 April 2013.
The Central Valley Water Board commits to supporting an Adaptive
Management approach. The adaptive management approach includes the
formation of a Stakeholder Group(s) and a Technical Advisory Committee
(TAC).
The study work plan will be reviewed and approval by the TAC and
subsequently approved by the Executive Officer. The Discharge shall
immediately implement the work plan upon Executive Officer approval, and a
progress report shall be submitted by 20 October 2015.
The Study shall evaluate the feasibility of reducing sources more than the
minimum amount needed to achieve the methylmercury allocation. The Study
also may include an evaluation of innovative actions, watershed approaches,
offsets projects, and other short and long-term actions that result in reducing
inorganic (total) mercury and methylmercury to address the accumulation of
methylmercury in fish tissue and to reduce methylmercury exposure. The
Study may evaluate the effectiveness of using inorganic (total) mercury controls
to control methylmercury discharges.
The Study shall include a description of methylmercury and/or inorganic (total)
mercury management practices identified in Phase 1; an evaluation of the
effectiveness, and costs, potential environmental effects, and overall feasibility
of the control actions. The Study shall also include proposed implementation
plans and schedules to comply with methylmercury allocations as soon as
possible. The Study shall be submitted by 20 October 2018.
The Executive Officer may authorize extending the Study due date. The
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CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
Executive Officer may, after public notice, extend the due date up to two years
if the Discharger demonstrates it is making significant progress towards
developing, implementing and/or completing the Study and reasonable
attempts have been made to secure funding for the Study, but the Discharger
has experienced severe budget shortfalls.
3. Best Management Practices and Pollution Prevention
c. Pollution Prevention Plan for Mercury. The Basin Plan’s Delta Mercury
Control Plan requires NPDES permitted facilities to submit and implement
pollutant minimization programs for mercury. The Discharger submitted a
pollution prevention plan for mercury dated 17 July 2012. The Discharger shall
update and implement a pollution prevention plan for mercury in accordance
with Water Code section 13263.3(d)(3), per the compliance schedule in this
Order for methylmercury (Section VI.C.7.a). The minimum requirements for the
pollution prevention plan are outlined in the Fact Sheet (Attachment F section
VII.B.3.c). Progress reports shall be submitted annually in accordance with the
Monitoring and Reporting Program (Attachment E section X.D.1.). The
progress reports shall discuss the effectiveness of the PPP in the reduction of
mercury in the discharge, include a summary of mercury and methylmercury
monitoring results, and discuss updates to the PPP.
d. Mercury Exposure Reduction Program. The Basin Plan’s Delta Mercury
Control Program requires dischargers to participate in a mercury Exposure
Reduction Program. The Exposure Reduction Program is needed to address
public health impacts of mercury in Delta fish, including activities that reduce
actual and potential exposure of and mitigate health impacts to those people
and communities most likely to be affected by mercury in Delta caught fish,
such as subsistence fishers and their families.
The Exposure Reduction Program must include elements directed toward:

Developing and implementing community-driven activities to reduce
mercury exposure;

Raising awareness of fish contamination issues among people and
communities most likely affected by mercury in Delta-caught fish such as
subsistence fishers and their families;

Integrating community-based organizations that serve Delta fish consumers,
Delta fish consumers, tribes, and public health agencies in the design and
implementation of an exposure reduction program;

Identifying resources, as needed, for community-based organizations and
tribes to participate in the Program;
Attachment F – Fact Sheet
F-101
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT

ORDER R5-2012-0115
NPDES NO. CA0079154
Utilizing and expanding upon existing programs and materials or activities in
place to reduce mercury, and as needed, create new materials or activities;
and
 Developing measures for program effectiveness.
This Order requires the Discharger participate in a mercury Exposure
Reduction Program in accordance with the Delta Mercury Control Program.
The Discharger, either individually or collectively with other Delta dischargers,
shall submit an exposure reduction work plan for Executive Officer approval by
20 October 2013. The objective of the Exposure Reduction Program is to
reduce mercury exposure of Delta fish consumers most likely affected by
mercury. The work plan shall address the Exposure Reduction Program
objective, elements, and the Discharger’s coordination with other stakeholders.
The Discharger shall integrate or, at minimum, provide good-faith opportunities
for integration of community-based organizations, tribes, and consumers of
Delta fish into planning, decision making, and implementation of exposure
reduction activities. The Discharger shall implement the work plan within
six months of Executive Officer Approval of the work plan.
c. Salinity Reduction Plan. The Discharger is required to maintain a Salinity
Reduction Plan submitted a Salinity Plan that describes the Discharger’s
approach to identify, evaluate, and implement measures to reduce salinity in
the effluent discharge to Old River. The Discharger shall submit annual
progress reports in accordance the Monitoring and Reporting Program
(Attachment E section X.D.1.). The Salinity Reduction Plan shall, at minimum,
contain the following:
i.
Pollution Prevention Plan (PPP). The Discharger submitted a PPP for
salinity on 17 July 2012 that meets the requirements of Water Code section
13263.3(d)(3). The Discharger shall continue to implement the PPP and
evaluate and update the PPP annually. The annual progress reports for the
Salinity Reduction Plan shall include a discussion of the effectiveness of the
PPP and any updates to the PPP.
ii.
Salinity Reduction Goal. The Central Valley Water Board finds that a
calendar annual average of 500 µmhos/cm as electrical conductivity
increase over the calendar annual weighted average electrical conductivity
of the City of Tracy’s water supply is a reasonable increase due to
consumptive use in the community. The annual progress reports for the
Salinity Reduction Plan shall include a discussion of the progress in meeting
the salinity reduction goal.
iii.
Best Practicable Treatment or Control (BPTC) Evaluation for Salinity.
The Discharger submitted a BPTC evaluation dated 13 September 2011.
By 1 September 2016, the Discharger shall update and submit a BPTC
evaluation for salinity that considers new information that was not available
at the time the September 2011 BPTC evaluation was developed.
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ORDER R5-2012-0115
NPDES NO. CA0079154
iv.
Central Valley Salinity Alternatives for Long-Term Sustainability
(CV-SALTS) Participation. The Discharger shall participate in CV-SALTS.
The annual progress reports for the Salinity Reduction Plan shall include a
discussion of the Discharger’s participation in CV-SALTS.
v.
Lower Salinity Water Supply Sources. The Salinity Reduction Plan shall
include a discussion of the Discharger’s efforts to obtain lower salinity water
supplies and the annual progress reports for the Salinity Reduction Plan
shall include a discussion of the Discharger’s efforts in this area.
The Discharger’s primary approach to reduce salinity in the wastewater effluent
has been to obtain surface water potable supplies to replace the use of the
salty native groundwater from municipal production wells. The Discharger
obtained additional surface water supplies, and in the span of just five years
reduced salt in the potable water supply by approximately 5,000 tons per year.
The following lists the chronology of the Discharger’s specific efforts to reduce
salt in the potable water supply:
1995
2001
2002
2005
2008
2013
Began project to bring South San Joaquin Irrigation District’s Stanislaus River water through 40
miles of pipeline to Tracy. In September 2005, water deliveries commenced.
Entered into long-term agreement to purchase additional surface water from the Delta-Mendota
Canal (DMC) to replace the highly saline native groundwater. Water became available in 2004.
Initiated design of an expansion to the potable water treatment plant in order to process the
additional DMC surface water. Construction was completed in 2007.
Successfully commenced a pilot project to store surplus surface water supplies in the Semitropic
Water Storage District in Kern County. The Discharger is currently preparing the environmental
documentation to allow permanent storage to increase the reliability of the DMC surface water
supplies and significantly reduce the need to utilize the highly saline native groundwater during
periods of drought or other water shortages.
Completed construction of a transmission pipeline that delivers the Stanislaus River water to a
second location within Tracy, which comprises 62% of the water customers served in 2009.
Discharger completed construction of an Aquifer Storage and Recovery (ASR) well pilot project in
2012. The Central Valley Water Board must approve pilot tests on injection of drinking water into
the groundwater basin. The permanent ASR project is planned for 2013 upon completion of
environmental review.
The Discharger’s efforts to obtain lower salinity water supplies has resulted in
reduced salinity levels as demonstrated in Figure F-3, below:
Attachment F – Fact Sheet
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ORDER R5-2012-0115
NPDES NO. CA0079154
Figure F-3
Total Dissolved Solids
Annual Average Discharge Concentration
The Discharger is also evaluating a desalination and green energy project. The
primary purpose of the proposed project is to construct and operate an
approximately 1.2 MGD desalination plant (Plant) in the City of Tracy. The
desalination plant would process treated effluent currently generated by the
Facility to a quality that is suitable for discharge into the Delta. Project
implementation would effectively remove salt from approximately 13 percent of
the Facility’s effluent. The treated desalination water would then be blended
back into the remaining Facility effluent prior to discharge into the Delta. The
newly blended and treated effluent will have lower salinity and will assist the
Discharger in compliance with all applicable Delta salinity standards.
The operation of the desalination plant will require a heat energy supply. The
proposed project includes a biomass cogeneration energy production
component. The biomass energy component would utilize available sources of
biomass, primarily agricultural residuals and urban wood waste, within a
50‐mile radius of the site. The biomass energy component would generate
approximately 16.4 megawatt-hours (MW/hr) of electricity, 15 MW/hr of which
would be distributed and sold to the local energy grid.
The Discharger has also been investigating the sources of salinity in an effort to
reduce concentrations to the Facility and is currently implementing a pollution
prevention plan (PPP) for salinity. Through its PPP, the Discharger concluded
that the primary controllable sources of salinity in the influent are “food
packaging industries and water softeners,” and that the “cheese processing
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NPDES NO. CA0079154
facility also appears to be a significant contributor of salinity.” The Discharger
completed and submitted a report in June 2011 that identified the sources of
salinity and appropriate pollution prevention activities to reduce generation or
discharge of salts.
Activities identified that could be undertaken to control salt discharges into the
Facility include the following: 1) Public outreach program informing the City’s
residents about the new and improved water quality, 2) Work in partnership
with water softener providers to advise residents of more appropriate devices,
3) Reduce infiltration and inflow along the domestic interceptor, 4) Implement
local limits for industries contributing salt to the Facility that is 10% or higher,
and 5) Under the pretreatment program, implement monitoring plans for users
that have a net contribution of salt to the Facility that is 10% or higher.
The Discharger conducted a Salinity Best Practical Treatment or Control Study,
which began in 2007 and concluded with a final report in September 2011. The
study concluded that the TDS species with the highest concentrations were
chloride, sulfate, and sodium. BMPs to reduce TDS concentrations included
discontinuing coagulant aid which caused an increase in chloride and improving
the disinfection process to reduce chlorine and sulfur dioxide use. The study
indicates the most significant reduction in EC since the salinity BPTC study
began is believed to be the result of increased water use from the South San
Joaquin Irrigation District (SSJID) for the water source improvement program.
Proven technologies were evaluated for salinity reduction including reverse
osmosis, electrodialysis reversal, and nanofiltration. The 30-year life cycle cost
analysis for these advanced treatment technologies resulted in estimated costs
higher than $170 million. After consideration of technical, economic,
environmental, and social factors, the salinity BPTC study concluded that
source control options are the best practical control methods for the City at this
time.
a. Water Code Section 13263.3(d)(3) Pollution Prevention Plans. A pollution
prevention plans for mercury and salinity are required in this Order per Water
Code section 13263.3(d)(1)(C). The minimum requirements for the pollution
prevention plans include the following:
i.
An estimate of all of the sources of a pollutant contributing, or potentially
contributing, to the loadings of a pollutant in the treatment plant influent.
ii.
An analysis of the methods that could be used to prevent the discharge of
the pollutants into the Facility, including application of local limits to
industrial or commercial dischargers regarding pollution prevention
techniques, public education and outreach, or other innovative and
alternative approaches to reduce discharges of the pollutant to the Facility.
The analysis also shall identify sources, or potential sources, not within
the ability or authority of the Discharger to control, such as pollutants in
the potable water supply, airborne pollutants, pharmaceuticals, or
Attachment F – Fact Sheet
F-105
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
pesticides, and estimate the magnitude of those sources, to the extent
feasible.
iii.
An estimate of load reductions that may be attained through the methods
identified in subparagraph ii.
iv.
A plan for monitoring the results of the pollution prevention program.
v.
A description of the tasks, cost, and time required to investigate and
implement various elements in the pollution prevention plan.
vi.
A statement of the Discharger’s pollution prevention goals and strategies,
including priorities for short-term and long-term action, and a description of
the Discharger’s intended pollution prevention activities for the immediate
future.
vii. A description of the Discharger’s existing pollution prevention programs.
viii. An analysis, to the extent feasible, of any adverse environmental impacts,
including cross-media impacts or substitute chemicals that may result from
the implementation of the pollution prevention program.
ix.
An analysis, to the extent feasible, of the costs and benefits that may be
incurred to implement the pollution prevention program.
4. Construction, Operation, and Maintenance Specifications
a. Turbidity Operational Requirements. Turbidity specifications have been
included in this Order as a second indicator of the effectiveness of the
treatment process and to assure compliance with the required level of
treatment. Failure of the filtration system such that virus removal is impaired
would normally result in increased particles in the effluent, which result in
higher effluent turbidity. Turbidity has a major advantage for monitoring filter
performance, allowing immediate detection of filter failure and rapid corrective
action. These operational turbidity specifications are necessary to assess
compliance with the DPH recommended Title 22 disinfection criteria, or
equivalent.
5. Special Provisions for Municipal Facilities (POTWs Only)
a. Pretreatment Requirements.
i.
The federal CWA section 307(b), and federal regulations,
40 CFR Part 403, require publicly owned treatment works to develop an
acceptable industrial pretreatment program. A pretreatment program is
required to prevent the introduction of pollutants, which will interfere with
treatment plant operations or sludge disposal, and prevent pass through of
pollutants that exceed water quality objectives, standards or permit
Attachment F – Fact Sheet
F-106
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
limitations. Pretreatment requirements are imposed pursuant to
40 CFR Part 403.
ii.
The Discharger shall implement and enforce its approved pretreatment
program and is an enforceable condition of this Order. If the Discharger
fails to perform the pretreatment functions, the Central Valley Water
Board, the State Water Board or USEPA may take enforcement actions
against the Discharger as authorized by the CWA.
b. Collection System. The State Water Board issued General Waste Discharge
Requirements for Sanitary Sewer Systems, Water Quality Order 2006-0003DWQ (General Order) on 2 May 2006. The General Order requires public
agencies that own or operate sanitary sewer systems with greater than one
mile of pipes or sewer lines to enroll for coverage under the General Order.
The General Order requires agencies to develop sanitary sewer management
plans (SSMPs) and report all sanitary sewer overflows (SSOs), among other
requirements and prohibitions.
Furthermore, the General Order contains requirements for operation and
maintenance of collection systems and for reporting and mitigating sanitary
sewer overflows. Inasmuch that the Discharger’s collection system is part of
the system that is subject to this Order, certain standard provisions are
applicable as specified in Provisions, section VI.C.5. For instance, the 24-hour
reporting requirements in this Order are not included in the General Order. The
Discharger must comply with this Order and separately with the requirements of
the General Order, which are not incorporated herein by reference. The
Discharger and public agencies that are discharging wastewater into the facility
were required to obtain enrollment for regulation under the General Order by
1 December 2006.
6. Other Special Provisions
a. Ownership Change. To maintain the accountability of the operation of the
Facility, the Discharger is required to notify the succeeding owner or operator of
the existence of this Order by letter if, and when, there is any change in control
or ownership of land or waste discharge facilities presently owned or controlled
by the Discharger.
7. Compliance Schedules
a. Compliance Schedule for Methylmercury. The State Water Board adopted
the Policy for Compliance Schedules in National Pollutant Discharge
Elimination System Permits (Resolution 2008-0025), which is the governing
Policy for compliance schedules in NPDES permits (hereafter “Compliance
Schedule Policy”). In accordance with the Compliance Schedule Policy and
40 C.F.R. § 122.47, a Discharger who seeks a compliance schedule must
demonstrate additional time is necessary to implement actions to comply with a
Attachment F – Fact Sheet
F-107
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
more stringent permit limitation. The Discharger must provide the following
documentation as part of the application requirements:
a) Diligent efforts have been made to quantify pollutant levels in the
discharge and the sources of the pollutant in the waste stream, and
the results of those efforts;
b) Source control efforts are currently underway or completed,
including compliance with any pollution prevention programs that
have established;
c) A proposed schedule for additional source control measures or
waste treatment;
d) Data demonstrating current treatment facility performance to
compare against existing permit effluent limits, as necessary to
determine which is the more stringent interim, permit effluent limit to
apply if a schedule of compliance is granted;
e) The highest discharge quality that can reasonably be achieved until
final compliance is attained;
f) The proposed compliance schedule is as short as possible, given
the type of facilities being constructed or programs being
implemented, and industry experience with the time typically
required to construct similar facilities or implement similar
programs; and
g) Additional information and analyses to be determined by the
Regional Water Board on a case-by-case basis.
Based on information submitted with the Report of Waste Discharge, selfmonitoring reports, pollution prevention plans, and other miscellaneous submittals,
it has been demonstrated to the satisfaction of the Central Valley Water Board that
the Discharger needs time to implement actions to comply with the new effluent
limitations for methylmercury.
The Delta Mercury Control Program is composed of two phases. Phase 1 spans
from 20 October 2011 through the Phase I Delta Mercury Control Program Review,
expected to conclude by October 2020. Phase 1 emphasizes studies and pilot
projects to develop and evaluate management practices to control methylmercury.
Phase 1 includes provisions for: implementing pollution minimization programs and
interim mass limits for inorganic (total) mercury point sources in the Delta and Yolo
Bypass; controlling sediment-bound mercury in the Delta and Yolo Bypass that
may become methylated in agricultural lands, wetland, and open-water habitats;
and reducing total mercury loading to San Francisco Bay, as required by the Water
Quality Control Plan for the San Francisco Bay Basin.
Attachment F – Fact Sheet
F-108
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
At the end of Phase 1, the Central Valley Water Board will conduct a Phase 1 Delta
Mercury Control Program Review that considers: modification of methylmercury
goals, objectives, allocations and/or the Final Compliance Date; implementation of
management practices and schedules for methylmercury controls; and adoption of
a mercury offset program for dischargers who cannot meet their load and waste
load allocations after implementing all reasonable load reduction strategies. The
review also will consider other potential public and environmental benefits and
negative impacts (e.g., habitat restoration, flood protection, water supply, fish
consumption) of attaining the allocations. The fish tissue objectives, the linkage
analysis between objectives and sources, and the attainability of the allocations will
be re-evaluated based on the findings of Phase 1 control studies and other
information. The linkage analysis, fish tissue objectives, allocations, and time
schedules shall be adjusted at the end of Phase 1, or subsequent program reviews,
if appropriate.
Phase 2 begins after the Phase 1 Delta Mercury Control Program Review or by
20 October 2022, whichever occurs first, and ends in 2030. During Phase 2,
dischargers shall implement methylmercury control programs and continue
inorganic (total) mercury reduction programs. Compliance monitoring and
implementation of upstream control programs also shall occur in Phase 2. Any
compliance schedule contained in an NPDES permit must be “…an enforceable
sequence of actions or operations leading to compliance with an effluent
limitation…” per the definition of a compliance schedule in CWA Section 502(17).
See also 40 C.F.R. § 122.2 (definition of schedule of compliance). The compliance
schedule for methylmercury meets these requirements.
Federal Regulations at 40 C.F.R. § 122.47(a)(1) requires that, “Any schedules of
compliance under this section shall require compliance as soon as possible…” The
Compliance Schedule Policy also requires that compliance schedules are as short
as possible and may not exceed 10 years, except when “…a permit limitation that
implements or is consistent with the waste load allocations specified in a TMDL that
is established through a Basin Plan amendment, provided that the TMDL
implementation plan contains a compliance schedule or implementation schedule.”
As discussed above, the Basin Plan’s Delta Mercury Control Program includes
compliance schedule provisions and allows compliance with the waste load
allocations for methylmercury by 2030. Until the Phase 1 Control Studies are
complete and the Central Valley Water Board conducts the Phase 1 Delta Mercury
Control Program Review, it is not possible to determine the appropriate compliance
date for the Discharger that is as soon as possible. Therefore, this Order
establishes a compliance schedule for the new, final, WQBELs for methylmercury
with full compliance required by 31 December 2030, which is consistent with the
Final Compliance Date of the TMDL. At completion of the Phase 1 Delta Mercury
Control Program Review, the final compliance date for this compliance schedule will
be re-evaluated to ensure compliance is required as soon as possible. Considering
the available information, the compliance schedule is as short as possible in
accordance with federal regulations and the Compliance Schedule Policy.
Attachment F – Fact Sheet
F-109
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
VIII. PUBLIC PARTICIPATION
The Central Valley Water Board is considering the issuance of WDRs that will serve as an
NPDES permit for the Facility. As a step in the WDR adoption process, the Central Valley
Water Board staff has developed tentative WDRs. The Central Valley Water Board
encourages public participation in the WDR adoption process.
A. Notification of Interested Parties
The Central Valley Water Board has notified the Discharger and interested agencies
and persons of its intent to prescribe waste discharge requirements for the discharge
and has provided them with an opportunity to submit their written comments and
recommendations. Notification was provided through publication of a Notice of Public
Hearing in the Tri Valley Herald.
B. Written Comments
The staff determinations are tentative. Interested persons are invited to submit written
comments concerning these tentative WDRs. Comments must be submitted either in
person or by mail to the Executive Office at the Central Valley Water Board at the
address above on the cover page of this Order.
To be fully responded to by staff and considered by the Central Valley Water Board,
written comments must be received at the Central Valley Water Board offices by
5:00 p.m. on 26 October 2012
C. Public Hearing
The Central Valley Water Board will hold a public hearing on the tentative WDRs during
its regular Board meeting on the following date and time and at the following location:
Date:
Time:
Location:
7 December 2012
8:30 a.m.
Regional Water Quality Control Board, Central Valley Region
11020 Sun Center Dr., Suite #200
Rancho Cordova, CA 95670
Interested persons are invited to attend. At the public hearing, the Central Valley
Water Board will hear testimony, if any, pertinent to the discharge, WDRs, and permit.
Oral testimony will be heard; however, for accuracy of the record, important testimony
should be in writing.
Please be aware that dates and venues may change. Our Web address is
www.waterboards.ca.gov/centralvalley where you can access the current agenda for
changes in dates and locations.
Attachment F – Fact Sheet
F-110
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
D. Waste Discharge Requirements Petitions
Any aggrieved person may petition the State Water Board to review the decision of the
Central Valley Water Board regarding the final WDRs. The petition must be received
by the State Water Board within 30 days of the Central Valley Water Board’s action,
and must be submitted to the following address:
State Water Resources Control Board
Office of Chief Counsel
P.O. Box 100, 1001 I Street
Sacramento, CA 95812-0100
E. Information and Copying
The Report of Waste Discharge, related documents, tentative effluent limitations and
special provisions, comments received, and other information are on file and may be
inspected at the address above at any time between 8:30 a.m. and 4:45 p.m., Monday
through Friday. Copying of documents may be arranged through the Central Valley
Water Board by calling (916) 464-3291.
F. Register of Interested Persons
Any person interested in being placed on the mailing list for information regarding the
WDRs and NPDES permit should contact the Central Valley Water Board, reference
this Facility, and provide a name, address, and phone number.
G. Additional Information
Requests for additional information or questions regarding this order should be
directed to Kari Holmes at (916) 464-4843.
Attachment F – Fact Sheet
F-111
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
G.
ATTACHMENT G – SUMMARY OF REASONABLE POTENTIAL ANALYSIS FOR CONSTITUENTS OF CONCERN 1
Constituent
Aluminum
Ammonia (as N)
Bis(2-ethylhexyl)phthalate
Chlorodibromomethane
Chlorpyrifos
Copper (total recoverable)
Diazinon
Dichlorobromomethane
Dissolved Oxygen
Iron (total recoverable)
Lead (total recoverable)
Manganese
Mercury (total recoverable)
Methylmercury
Nitrate + Nitrite (as N)
Units
MEC
B
C
CMC
CCC
Water & Org
Org. Only
mg/L
mg/L
µg/L
µg/L
µg/L
µg/L
µg/L
µg/L
mg/L
µg/L
µg/L
µg/L
ng/L
ng/L
mg/L
310
3.6
12
23
1900
1
0.6
0.5
200
750
750
N/A
N/A
5.9
7
29
0.5
1.8
0.41
0.1
3.8
0.015
0.56
N/A
N/A
0.02
5.2
0.08
N/A
N/A
N/A
0.014
3.8
0.05
N/A
1.8
0.41
N/A
1300
N/A
0.56
5.9
34
N/A
N/A
N/A
46
54
4000
1.5
290
0.008
0.18
300
0.8
50
2
N/A
21
N/A
N/A
1000
0.8
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
100
N/A
10
N/A
N/A
N/A
N/A
20
0.18
0.22
General Note: All inorganic concentrations are given as a total recoverable.
MEC = Maximum Effluent Concentration
B = Maximum Receiving Water Concentration or lowest detection level, if non-detect
C = Criterion used for Reasonable Potential Analysis
CMC = Criterion Maximum Concentration (CTR or NTR)
CCC = Criterion Continuous Concentration (CTR or NTR)
Water & Org = Human Health Criterion for Consumption of Water & Organisms (CTR or NTR)
Org. Only = Human Health Criterion for Consumption of Organisms Only (CTR or NTR)
Basin Plan = Numeric Site-specific Basin Plan Water Quality Objective
MCL = Drinking Water Standards Maximum Contaminant Level
NA = Not Available
ND = Non-detect
Attachment G – Summary of Reasonable Potential Analysis
Basin
Plan
N/A
N/A
N/A
0.1
10
0.015
N/A
1
5
300
N/A
50
N/A
2
0.77
N/A
MCL
200
4
80
N/A
1000
N/A
80
300
15
50
2
10
Reasonable
Potential
No
Yes
Yes
Yes
Limited Data
Yes
Limited Data
Yes
No
No
Limited Data
No
Yes
Yes
Yes
Footnotes:
(1) Dissolved oxygen concentrations shall not be reduced below 5
mg/L.
(2) The total calendar annual load of methylmercury shall not exceed
0.77 grams.
G-1
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
H.
ATTACHMENT H – CALCULATION OF WQBELS
H-1
AMEL
Multiplier95
AMELAL
MDEL
Multiplier99
MDELAL
Lowest AMEL
Lowest MDEL
Lowest LTA
LTAchronic
c
ECA
Multiplierchroni
LTAacute
ECA
Multiplieracute
Ammonia Nitrogen, Total (as
mg/L
-2.14 1.42
------0.54
1.2
0.89
1.3
1.2
N)
Bis (2-ethylhexyl) phthalate
µg/L
1.8
--7.5:1 --12.19
3.99
48.7
-----1
Copper (total recoverable)
µg/L
-10.4
-------0.44
11.9
0.65
10.91
10.91
Chlorodibromomethane
µg/L 0.41
--20:1
--8.01
2.21
18
-----Dichlorobromomethane
µg/L 0.56
--20:1
--10.56
2.19
23
-----1
A more stringent MDEL of 10.4 µg/L is established in this Order based on the Basin Plan Objective (see Section IV.c.3.d.iv of the Fact Sheet for a detailed discussion).
Attachment H – Calculation of WQBELs
Final Effluent
Limitations
Aquatic Life Calculations
MDELHH
AMEL/MDEL
MultiplierHH
ECAHH =
AMELHH
HH Calculations
CCC
CMC
Dilution
Factors
HH
CCC
Units
CMC
Parameter
HH
Most Stringent
Criteria
1.13
1.3
1.84
2.1
1.3
2.1
-1.36
---
-15
---
-2.26
---
-25
---
12
15
8
11
49
1
10.4
18
23
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
I.
ATTACHMENT I – EFFLUENT AND RECEIVING WATER CHARACTERIZATION STUDY
I. Background. Sections 2.4.1 through 2.4.4 of the SIP provide minimum standards for
analyses and reporting. (Copies of the SIP may be obtained from the State Water
Resources Control Board, or downloaded from
http://www.waterboards.ca.gov/iswp/index.html). To implement the SIP, effluent and
receiving water data are needed for all priority pollutants. Effluent and receiving water pH
and hardness are required to evaluate the toxicity of certain priority pollutants (such as
heavy metals) where the toxicity of the constituents varies with pH and/or hardness.
Section 3 of the SIP prescribes mandatory monitoring of dioxin congeners. In addition to
specific requirements of the SIP, the Central Valley Water Board is requiring the following
monitoring:
A. Drinking water constituents. Constituents for which drinking water Maximum
Contaminant Levels (MCLs) have been prescribed in the California Code of Regulation
are included in the Water Quality Control Plan, Fourth Edition, for the Sacramento and
San Joaquin River Basins (Basin Plan). The Basin Plan defines virtually all surface
waters within the Central Valley Region as having existing or potential beneficial uses
for municipal and domestic supply. The Basin Plan further requires that, at a minimum,
water designated for use as domestic or municipal supply shall not contain
concentrations of chemical constituents in excess of the MCLs contained in the
California Code of Regulations.
B. Effluent and receiving water temperature. This is both a concern for application of
certain temperature-sensitive constituents, such as fluoride, and for compliance with the
Basin Plan’s thermal discharge requirements.
C. Effluent and receiving water hardness and pH. These are necessary because
several of the CTR constituents are hardness and pH dependent.
D. Dioxin and furan sampling. Section 3 of the SIP has specific requirements for the
collection of samples for analysis of dioxin and furan congeners, which are detailed in
Attachment J. Pursuant to Section 13267 of the California Water Code, this Order
includes a requirement for the Discharger to submit monitoring data for the effluent and
receiving water as described in Attachment J.
II. Monitoring Requirements.
A. Bi-Monthly Monitoring. Bi-monthly (i.e., every other month) samples shall be
collected from the effluent and upstream receiving water (EFF-001 and RSW-001) and
analyzed for the constituents listed in Table I-1. Bi-monthly monitoring shall be
conducted for 1 year, during the third or fourth year of the permit term (i.e., 6 samples,
collected every other month for one year) and the results of such monitoring shall be
submitted to the Central Valley Water Board within 6 months of the final monitoring
event. Each individual monitoring event shall provide representative sample results for
the effluent and upstream receiving water.
Attachment I – Effluent and Receiving Water Characterization Study
I-1
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
B. Annual Dry Weather Monitoring (dioxins and furans only). Annual dry weather
monitoring is required during the term of this Order for three consecutive years for
dioxins and furans, as specified in Attachment J. The results of dioxin and furan
monitoring shall be submitted to the Central Valley Water Board with the monitoring
data discussed in subsection A, above.
C. Concurrent Sampling. Effluent and receiving water sampling shall be performed at
approximately the same time, on the same date.
D. Sample type. All effluent samples shall be taken as 24-hour flow proportioned
composite samples. All receiving water samples shall be taken as grab samples.
E. Additional Monitoring/Reporting Requirements. The Discharger shall conduct the
monitoring and reporting in accordance with the General Monitoring Provisions and
Reporting Requirements in Attachment E.
Table I-1. Priority Pollutants and Other Constituents of Concern
CTR
#
CAS
Number
µg/L or noted
28
1,1-Dichloroethane
75343
1
30
1,1-Dichloroethene
75354
0.5
41
1,1,1-Trichloroethane
71556
2
42
1,1,2-Trichloroethane
79005
0.5
37
1,1,2,2-Tetrachloroethane
79345
0.5
75
1,2-Dichlorobenzene
95501
2
29
1,2-Dichloroethane
107062
0.5
cis-1,2-Dichloroethene
156592
1,2-Dichloropropane
78875
0.5
101 1,2,4-Trichlorobenzene
120821
1
76
1,3-Dichlorobenzene
541731
2
32
1,3-Dichloropropene
542756
0.5
77
1,4-Dichlorobenzene
106467
2
17
Acrolein
107028
2
18
Acrylonitrile
107131
2
19
Benzene
71432
0.5
20
Bromoform
75252
2
34
Bromomethane
74839
2
21
Carbon tetrachloride
56235
0.5
31
1
Constituent
Maximum
Reporting
1
Level
The reporting levels required in these tables for priority pollutant constituents are established based on Section 2.4.2 and
Appendix 4 of the SIP.
Attachment I – Effluent and Receiving Water Characterization Study
I-2
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
CTR
#
ORDER R5-2012-0115
NPDES NO. CA0079154
Maximum
Reporting
1
Level
CAS
Number
µg/L or noted
108907
2
22
Constituent
Chlorobenzene (mono
chlorobenzene)
24
Chloroethane
75003
2
25
2- Chloroethyl vinyl ether
110758
1
26
Chloroform
67663
2
35
Chloromethane
74873
2
23
Dibromochloromethane
124481
0.5
27
Dichlorobromomethane
75274
0.5
36
Dichloromethane
75092
2
33
Ethylbenzene
100414
2
88
Hexachlorobenzene
118741
1
89
Hexachlorobutadiene
87683
1
91
Hexachloroethane
67721
1
94
Naphthalene
91203
10
38
Tetrachloroethene
127184
0.5
39
Toluene
108883
2
40
trans-1,2-Dichloroethylene
156605
1
43
Trichloroethene
79016
2
44
Vinyl chloride
75014
0.5
Methyl-tert-butyl ether (MTBE)
1634044
Trichlorofluoromethane
1,1,2-Trichloro-1,2,2Trifluoroethane
75694
Styrene
100425
Xylenes
1330207
76131
60
1,2-Benzanthracene
56553
5
85
1,2-Diphenylhydrazine
122667
1
45
2-Chlorophenol
95578
5
46
2,4-Dichlorophenol
120832
5
47
2,4-Dimethylphenol
105679
2
49
2,4-Dinitrophenol
51285
5
82
2,4-Dinitrotoluene
121142
5
55
2,4,6-Trichlorophenol
88062
10
83
2,6-Dinitrotoluene
606202
5
50
2-Nitrophenol
25154557
10
71
2-Chloronaphthalene
91587
10
78
3,3'-Dichlorobenzidine
91941
5
62
3,4-Benzofluoranthene
205992
10
Attachment I – Effluent and Receiving Water Characterization Study
I-3
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
CTR
#
Constituent
ORDER R5-2012-0115
NPDES NO. CA0079154
Maximum
Reporting
1
Level
CAS
Number
µg/L or noted
52
4-Chloro-3-methylphenol
59507
5
48
4,6-Dinitro-2-methylphenol
534521
10
51
4-Nitrophenol
100027
10
69
4-Bromophenyl phenyl ether
101553
10
72
4-Chlorophenyl phenyl ether
7005723
5
56
Acenaphthene
83329
1
57
Acenaphthylene
208968
10
58
Anthracene
120127
10
59
92875
5
61
Benzidine
Benzo(a)pyrene (3,4Benzopyrene)
50328
2
63
Benzo(g,h,i)perylene
191242
5
64
Benzo(k)fluoranthene
207089
2
65
Bis(2-chloroethoxy) methane
111911
5
66
Bis(2-chloroethyl) ether
111444
1
67
Bis(2-chloroisopropyl) ether
39638329
10
68
Bis(2-ethylhexyl) phthalate
117817
5
70
Butyl benzyl phthalate
85687
10
73
Chrysene
218019
5
81
Di-n-butylphthalate
84742
10
84
Di-n-octylphthalate
117840
10
74
Dibenzo(a,h)-anthracene
53703
0.1
79
Diethyl phthalate
84662
10
80
Dimethyl phthalate
131113
10
86
Fluoranthene
206440
10
87
Fluorene
86737
10
90
Hexachlorocyclopentadiene
77474
5
92
Indeno(1,2,3-c,d)pyrene
193395
0.05
93
Isophorone
78591
1
98
N-Nitrosodiphenylamine
86306
1
96
N-Nitrosodimethylamine
62759
5
97
N-Nitrosodi-n-propylamine
621647
5
95
Nitrobenzene
98953
10
53
Pentachlorophenol
87865
1
99
Phenanthrene
85018
5
54
Phenol
108952
1
100 Pyrene
129000
10
Attachment I – Effluent and Receiving Water Characterization Study
I-4
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
CTR
#
Constituent
ORDER R5-2012-0115
NPDES NO. CA0079154
CAS
Number
Maximum
Reporting
1
Level
µg/L or noted
Aluminum
7429905
1
Antimony
7440360
5
2
Arsenic
7440382
10
15
Asbestos
1332214
Barium
7440393
3
Beryllium
7440417
2
4
Cadmium
7440439
0.5
5a
Chromium (III)
16065831
50
5b
Chromium (VI)
18540299
10
6
Copper
7440508
0.5
14
Cyanide
57125
5
Fluoride
7782414
Iron
7439896
7
Lead
7439921
0.5
8
Mercury
7439976
0.5
Manganese
7439965
Molybdenum
7439987
9
Nickel
7440020
20
10
Selenium
7782492
5
11
Silver
7440224
0.25
12
Thallium
7440280
1
Tributyltin
688733
Zinc
7440666
20
110 4,4'-DDD
72548
0.05
109 4,4'-DDE
72559
0.05
108 4,4'-DDT
50293
0.01
112 alpha-Endosulfan
alpha-Hexachlorocyclohexane
103 (BHC)
959988
0.02
319846
0.01
13
Alachlor
102 Aldrin
15972608
309002
0.005
33213659
0.01
104 beta-Hexachlorocyclohexane
319857
0.005
107 Chlordane
57749
0.1
106 delta-Hexachlorocyclohexane
319868
0.005
111 Dieldrin
60571
0.01
1031078
0.05
113 beta-Endosulfan
114 Endosulfan sulfate
Attachment I – Effluent and Receiving Water Characterization Study
I-5
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
CTR
#
ORDER R5-2012-0115
NPDES NO. CA0079154
Maximum
Reporting
1
Level
CAS
Number
µg/L or noted
72208
0.01
7421934
0.01
76448
0.01
118 Heptachlor Epoxide
Lindane (gamma105 Hexachlorocyclohexane)
1024573
0.01
58899
0.02
119 PCB-1016
12674112
0.5
120 PCB-1221
11104282
0.5
121 PCB-1232
11141165
0.5
122 PCB-1242
53469219
0.5
123 PCB-1248
12672296
0.5
124 PCB-1254
11097691
0.5
125 PCB-1260
11096825
0.5
126 Toxaphene
8001352
0.5
Constituent
115 Endrin
116 Endrin Aldehyde
117 Heptachlor
Atrazine
1912249
Bentazon
25057890
Carbofuran
1563662
2,4-D
94757
Dalapon
1,2-Dibromo-3-chloropropane
(DBCP)
75990
Di(2-ethylhexyl)adipate
103231
Dinoseb
88857
Diquat
85007
Endothal
145733
Ethylene Dibromide
106934
Glyphosate
1071836
Methoxychlor
16
96128
72435
Molinate (Ordram)
2212671
Oxamyl
23135220
Picloram
1918021
Simazine (Princep)
122349
Thiobencarb
28249776
2,3,7,8-TCDD (Dioxin)
1746016
2,4,5-TP (Silvex)
93765
Diazinon
333415
Chlorpyrifos
2921882
Ammonia (as N)
7664417
Attachment I – Effluent and Receiving Water Characterization Study
I-6
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
CTR
#
Constituent
Chloride
ORDER R5-2012-0115
NPDES NO. CA0079154
CAS
Number
Maximum
Reporting
1
Level
µg/L or noted
16887006
Flow
Hardness (as CaCO3)
Foaming Agents (MBAS)
Mercury, Methyl
22967926
Nitrate (as N)
14797558
Nitrite (as N)
14797650
pH
Phosphorus, Total (as P)
7723140
Specific conductance (EC)
Sulfate
Sulfide (as S)
Sulfite (as SO3)
Temperature
Total Dissolved Solids (TDS)
Total Organic Kjeldahl Nitrogen
Total Organic Carbon
Dissolved Organic Carbon
Attachment I – Effluent and Receiving Water Characterization Study
I-7
CITY OF TRACY
TRACY WASTEWATER TREATMENT PLANT
ORDER R5-2012-0115
NPDES NO. CA0079154
J.
ATTACHMENT J – DIOXIN AND FURAN SAMPLING
The CTR includes criteria for 2,3,7,8-tetrachlorodibenzo-pdioxin (2,3,7,8-TCDD). In addition to
this compound, there are many congeners of chlorinated dibenzodioxins (2,3,7,8-CDDs) and
chlorinated dibenzofurans (2,3,7,8-CDFs) that exhibit toxic effects similar to those of 2,3,7,8TCDD. The USEPA has published toxic equivalency factors (TEFs) for 17 of the congeners.
The TEFs express the relative toxicities of the congeners compared to 2,3,7,8-TCDD (whose
TEF equals 1.0). In June 1997, participants in a World Health Organization (WHO) expert
meeting revised TEF values for 1,2,3,7,8-PentaCDD, OctaCDD, and OctaCDF. The current
TEFs for the 17 congeners, which include the three revised values, are shown below:
Toxic Equivalency Factors (TEFs) for 2,3,7,8-TCDD Equivalents
Congener
TEF
2,3,7,8-TetraCDD
1
1,2,3,7,8-PentaCDD
1.0
1,2,3,4,7,8-HexaCDD
0.1
1,2,3,6,7,8-HexaCDD
0.1
1,2,3,7,8,9-HexaCDD
0.1
1,2,3,4,6,7,8-HeptaCDD
0.01
OctaCDD
0.0001
2,3,7,8-TetraCDF
0.1
1,2,3,7,8-PentaCDF
0.05
2,3,4,7,8-PentaCDF
0.5
1,2,3,4,7,8-HexaCDF
0.1
1,2,3,6,7,8-HexaCDF
0.1
1,2,3,7,8,9-HexaCDF
0.1
2,3,4,6,7,8-HexaCDF
0.1
1,2,3,4,6,7,8-HeptaCDF
0.01
1,2,3,4,7,8,9-HeptaCDF
0.01
OctaCDF
0.0001
The Discharger shall conduct effluent and receiving water monitoring for the 2,3,7,8-TCDD
congeners listed above to assess the presence and amounts of the congeners being
discharged and already present in the receiving water. Effluent and upstream receiving water
shall be monitored for the presence of the 17 congeners once annually during dry weather for
three consecutive years.
The Discharger shall report, for each congener, the analytical results of the effluent and
receiving water monitoring, including the quantifiable limit and the method detection limit, and
the measured or estimated concentration.
In addition, the Discharger shall multiply each measured or estimated congener concentration
by its respective TEF value and report the sum of these values.
Attachment J – Dioxin and Furan Sampling
J-1